Q. Is an NASD member firm responsible for reviewing and approving advertisements and sales literature its representatives may use regarding fixed annuities?
A. The member firm would not be required to approve communications about fixed annuities sold through a non-member entity. Nevertheless, registered individuals must recognize that they have a responsibility under NASD Conduct Rule 2210 to ensure that all of their communications regarding financial products and services are fair and not misleading, regardless of whether the product is sold through an NASD member firm or not. In addition, registered individuals must provide prompt written notice to their member firms of this type of outside business activity as required by NASD Conduct Rule 3030.