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The question of whether a particular person is required to obtain a series 63 license is a specific facts and circumstances analysis, and ultimately would be answered by state law or regulations of each individual state involved.
Factors that may determine whether research personnel are required to be registered include their communications with customers, making of recommendations, accepting or executing orders for the purchase or sale of securities, and method of compensation.
<p>In an order settling an enforcement action by the Commodity Futures Trading Commission, an undertaking not to apply for registration for period of three years operates as the functional equivalent of an order suspending registration. One who consents to such an undertaking is statutorily disqualified from registration under Article III, Section 4 of the NASD By-Laws.<br />
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Exemptive relief is granted based on the determination that the dealer: (1) had developed and instituted procedures reasonably designed to ensure compliance with the rule; (2) had no actual knowledge of the contribution prior to or at the time of the contribution; (3) had taken all available steps to cause the person involved in making the contribution to obtain a return of the contribution; and (4) had taken such other remedial or preventative measures as were appropriate under the circumstances.
It appears that the violation of the Rule, as described in your letter, relates directly to the failure of the firm to develop and institute procedures reasonably designed to ensure compliance of the Rule i.e., for the review and approval of political contributions by a municipal finance professional prior to making the contribution. Accordingly, the firm's request for an exemption is denied.
The request for exemptive relief is denied. You represent that Firm had established comprehensive and detailed procedures which included the requirement to pre-clear political contributions. Indeed, the firm’s procedures were attached to your exemption request as "Attachment No. 2," and they require that "all public finance employees" of the firm obtain prior approval of political contributions. The CEO did not follow the firm’s established procedures. This lapse by a senior official is significant and leads us to conclude that the request for an exemption should be denied.
Exemptive relief is granted based on the following considerations: (1.) the de minimis nature of the Proposed Hire’s Contribution made more than one year ago; (2.) the Contribution was made by an individual who has never been employed in the municipal securities business.
Exemptive relief is granted based on the following considerations: (1.) the de minimis nature of the Contribution mitigates the probability that the payment will improperly influence issuer officials; (2.) the Contribution was made by an individual who has never been employed in the municipal securities business.
An exemption is granted based on consideration of the MSRB’s published interpretation of Rule G-37 regarding mergers of corporations in the municipal securities industry3 and on your representation that Individual will not be engaged in helping Firm A obtain municipal securities business or engaged in municipal securities representative activities before September 24, 2001, when the two-year ban under Rule G-37 would otherwise expire.
Exemptive relief is granted based on the following considerations: the Contribution was made by an individual who, at of the time of the Contribution, had never been an MFP nor was Name involved in the Firm’s municipal securities business. We believe the possibility that the payment was intended to influence issuer officials is significantly minimized. To the extent that any potential investor protection concerns exist, the staff believes these concerns will be appropriately addressed by the Firm’s existing firewall procedures for Name.