Comments on NASD Notice to Members 05-40

Monday, July 18, 2005


Clarification of the exception in Rule 2311 (b)(2) "An occasional meal, a ticket to a sporting event or the theater, or comparable entertainment..."


There is an Interpretive Letter dated 06/10/1999 to a Director and VP of T Rowe Price where this is addressed. It states in this Interpretive Letter that If a person associated with a member is not personally hosting the business entertainment, than it would fall under Rule 3060.


If this is a correct interpretation of the rule, then would the NASD incorporate this into the new rule 2311 to make it clearer.



Dawn Welling

Compliance Analyst

United Securities Alliance, Inc.

7730 E Belleview Ave, Suite AG-9

Greenwood Village, CO  80111