NASD Notice to Members 04-75 - October 2004

NASD Seeks Comment on Enhanced Disclosure for Subordination Agreements; Comment Period Expires November 26, 2004

Executive Summary

In 2002, NASD adopted a requirement that firms submitting subordination agreements to NASD staff for approval provide each investor with a Subordination Agreement Investor Disclosure Document (Disclosure Document), a signed copy of which must be provided to NASD staff before the agreement will be approved.


The purpose of the Disclosure Document is to help investors understand what a subordination agreement is and what risks investors assume when they enter into such agreements.


Questions concerning this Notice may be directed to Gary L. Goldsholle, Associate Vice President and Associate General Counsel, Office of General Counsel, Regulatory Policy and Oversight (RPO), at (202) 728-8104; or Brant K. Brown, Counsel, Office of General Counsel, RPO, at (202) 728-6927.

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The views, expressions, findings and opinions expressed in the comments on this Web page are solely those of the author(s) and FINRA accepts no responsibility for the content of the comments.

Comments By Date Received
Caldwell Securities, Incorporated (PDF 29 KB) 10/14/2004
Nancy P. Mills (PDF 28 KB) 10/21/2004
John Moloney (PDF KB) 11/24/2004
The Jeffrey Matthews Financial Group, LLC (PDF 12 KB) 11/24/2004
Integrated Management Solutions (PDF 17 KB) 11/26/2004