RCA - July 1996 - Ask The Analyst - Filing Requirements
If a full-service broker/dealer uses a WWW site describing the services it provides, including references to mutual funds from its fund family, is this considered mutual fund advertising and must it be, filed within 10 days of first use? A:
If the site merely mentions the fact that the member firm offers mutual funds, it would not have to be submitted for review to NASD Regulation. However, if the site goes on to describe the funds and/or discuss them by name, then the material would require filing as a mutual fund advertisement. As discussed in the April 1996 Regulatory & Compliance Alert
, communications made generally available on the WWW or commercial on-line services constitute advertisements.