Neutral Corner - February 2008
TO: All NASD Members and Other Interested Persons
EXECUTIVE SUMMARY
The NASD wishes to apprise its members of the SEC's recent release relating to mark-ups on zero-coupon securities. The SEC has become aware of potential abuses in this area and emphasizes that applicable provisions of the federal securities laws, NASD rules, and MSRB rules apply equally to zero-coupon securities. The SEC
JOINT REQUEST FOR COMMENT
SUGGESTED ROUTING
KEY TOPICS
Legal & Compliance
Operations
Registered Representatives
Senior Management
Training
Correspondence—General
Electronic CommunicationsRule 2210 (Communications with the Public)Rule 2211 (Institutional Sales Material and Correspondence)Rule 3010 (Supervision) Supervision
Supervision of Electronic
SUGGESTED ROUTING*
Senior Management
Institutional
Legal & Compliance
Research
*These are suggested departments only. Others may be appropriate for your firm.
IMPORTANT MAIL VOTE
EXECUTIVE SUMMARY
NASD members are invited to vote on a proposed amendment to Article III, Section 24(b) of the
Summary
FINRA is soliciting comment on a proposal to amend FINRA Uniform Practice Code Rule 11880 (Settlement of Syndicate Accounts). The proposed amendments would reduce the maximum time for the final settlement of syndicate accounts in a public offering of corporate debt securities from 90 days to 30 days following the syndicate settlement date.
Questions concerning this Notice should be
TO: All NASD Members, Associated Persons and Other Interested Persons
EXECUTIVE SUMMARY
NASD rules and policies consider associated persons of a member to be employees of the member, regardless of their locations or compensation arrangements. The notice addresses regulatory issues that relate to off-site employment of registered persons, including supervisory procedures, private securities
TO: All NASD Members and Other Interested Persons
ATTN: Corporate Financing Department
The National Association of Securities Dealers, Inc. (NASD), has adopted amendments to the Filing Requirements Section of the Interpretation of the Board of Governors — Review of Corporate Financing, Article III, Section 1 of the NASD Rules of Fair Practice (Corporate Financing Interpretation) which are
Regulatory Obligations
FINRA Rule 2090 (Know Your Customer) requires member firms and their associated persons to use reasonable diligence to determine the “essential facts” about every customer and “the authority of each person acting on behalf of such customer.” Regulatory Notice 11-02 (SEC Approves Consolidated FINRA Rules Governing Know-Your-Customer and Suitability Obligations) advised that
FINRA’s Risk Monitoring and Examination Programs evaluate member firms for compliance with relevant obligations and consider specific risks relating to each firm, including those relating to a firm’s business model, supervisory control system and prior exam findings, among other considerations. While the topics addressed in this Report are selected for their interest to the largest number of
(a) Member Surcharge
(1) A surcharge in the amount indicated in the schedule below will be assessed against each member that:
(A) Files a claim, counterclaim, cross claim, or third party claim under the Code;
(B) Is named as a respondent in a claim, counterclaim, cross claim, or third party claim filed and served under the Code; or
(C) Employed, at the time the dispute arose, an associated
