Exemptive relief is granted based on: representations that at the time of the contribution the individual was not employed by the firm, was not an MFP, and did not anticipate an employment relationship with the firm; the firm already had a significant business relationship with the City of which the contribution recipient is an issuer official (as defined); the individual has attempted to obtain the return of the contribution; the firm has instituted barriers and controls around certain municipal business communications; and the individual will be prohibited from any involvement in municipal securities business with the City for a period of time.
GUIDANCE
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KEY TOPICS
Legal & Compliance
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Registered Representatives
Senior Management
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NASDAQ Exchange Registration
Executive Summary
On July 5, 2006, The NASDAQ Stock Market, Inc. ("NASDAQ")
announced that it would begin to operate as a national securities
exchange on August 1, 2006 for NASDAQ-
SEC Approves Amendments to FINRA Rule 8313 (Release of Disciplinary Complaints, Decisions and Other Information)
FINRA Small Firm Advisory Board Election
FINRA Provides Guidance on Application of Communications Rules to Disclosures Required by Department of Labor
FINRA Provides Guidance on Advertising Regulation Issues
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.
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.
Five-Day Period for Replies to Responses to Motions in Arbitration
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.
