This request for exemptive relief is granted based on the representations that the Contributions were made prior to the individual's employment with the Firm, and the individual has never been involved in municipal securities business as defined by MSRB Rule G-37. Additionally, the Firm has agreed to institute information barriers and compensation restrictions, and the contributions have been returned.
This request for exemptive relief is granted based on the Firm's representation that the contributor has never solicited municipal securities business, as defined by MSRB Rule G-37, from the State or entities or agencies connected with the State of whom the contribution recipient is considered to be an issuer official, the Contribution was returned, and representations that the Firm has imposed certain limitations on the individual's municipal business solicitation, and receipt of compensation from the Firm's municipal securities business with the State or State agencies.
GUIDANCE
Supervisory Controls
SUGGESTED ROUTING
KEY TOPICS
Legal & Compliance
Operations
Registered Representatives
Senior Management
Trading
Institutional Securities Activities
Rule 3012
(Supervisory Control System)
Rule 3010 (Supervision)
Supervisory Control Procedures
Written Supervisory Procedures
Executive Summary
On September 30, 2004, the
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An exemption is granted based on the following considerations. First, you have represented that Name, prior to being hired by the Firm, was not engaged in the solicitation of municipal securities business, as defined in the Rule. Second, you have represented that the Firm has a long relationship as an underwriter of municipal securities for the State and State agencies, and neither the hiring of Name nor his Contribution was necessary to obtain municipal securities business from such issuers. Third, the Firm has agreed to institute preventive information barriers to help avoid the potential for conflicting interests to exist and be used, or appear to be used, by the Firm or Name to obtain municipal securities business or compensation or other financial benefits related to such business.
TO: All NASD Members and Other Interested Persons
EXECUTIVE SUMMARY
The Department of the Treasury is soliciting comments on proposed amendments to the implementing regulations of the Bank Secrecy Act. Also known as the Currency and Foreign Transactions Reporting Act of 1970, these regulations govern the payment, receipt or transfer of currency or other monetary instruments; the export or import
This request for exemptive relief is granted based on the Firms’ representation that the Contribution was made by an employee who does not and has never engaged in the solicitation of municipal securities business, the imposition of certain “information restrictions” and other Firm-wide compliance measures, a Firm- imposed “censure” and compensation restrictions, and the return of the Contribution.
GUIDANCE
Expungement
SUGGESTED ROUTING
KEY TOPICS
Legal & Compliance
Registered Representatives
Senior Management
Affidavits
Arbitration
Central Registration Depository System (CRD® or CRD system)
Customer Dispute Information
Dispute Resolution
Expungement
Rule 2110
Rule 2130
Executive Summary
On
Regarding section D. "Information on Allocations of Fail-to-Deliver Positions" in the sections marked as "Identify of correspondent firm" and "Amount allocated to correspondent firm (number of shares). I believe that what constitutes a "Correspondent firm" and who this refers to exactly need to be more accurately defined in order to avoid misreporting or
INFORMATIONAL
Instant Messaging
SUGGESTED ROUTING
KEY TOPICS
Legal and Compliance
Senior Management
Operations
Trading and Market Making
Electronic Communications
Communications with the Public
Recordkeeping
Executive Summary
NASD is clarifying for members their supervisory obligations and recordkeeping requirements
