| NASD Rule 2110 - Standards of Commercial Honor and Principles of Trade |
|
8/15/06
|
NASD Office of General Counsel, Regulatory Policy and Oversight
|
|
6/2/06
|
Submitted by Michael R. Trocchio, Esq., Bingham McCutchen LLP
|
|
2/3/05
|
Submitted by Michael R. Trocchio, Esq., Bingham McCutchen LLP
|
|
11/10/04
|
Submitted by Michael R. Trocchio, Esq., Bingham McCutchen LLP
|
|
11/8/04
|
NASD Office of General Counsel, Regulatory Policy and Oversight
|
|
10/20/04
|
Submitted by Barry Harris, Banc of America Investment Services, Inc. (Use of Negative Response Letters)
|
|
5/1/03
|
Submitted by Michael D. Wolk, Esq., Foley and Lardner (Use of Negative Response Letters)
|
|
2/3/03
|
Submitted by Doug Wright, The Investment Center, Inc. (Use of Negative Response Letters)
|
|
2/3/03
|
Submitted by Marion A. Kashan, London Pacific Securities, Inc. (Use of Negative Response Letters)
|
|
12/12/02
|
Submitted by R. Cromwell Coulson, Pink Sheets LLC
|
|
3/19/01
|
Submitted by Klia Ververidis, Esq., AssetStream Corporation
|
|
12/22/00
|
Submitted by Barbara A. Mallon, Esq., Mallon & Johnson, P.C.
|
|
10/16/00
|
Submitted by Justine Rusin, Merit Capital Associates, Inc. (Use of Negative Response Letters)
|
| |
| NASD IM-2110-2 - Trading Ahead of Customer Limit Order |
|
7/3/97
|
Name Not Public
|
|
4/16/97
|
Name Not Public
|
| |
| NASD Rule 2120 - Use of Manipulative, Deceptive, or Other Fraudulent Devices |
|
8/29/97
|
Submitted by Lloyd H. Feller, Morgan, Lewis & Bockius
|
| |
| NASD Rule 2210 - Communications with the Public |
|
9/28/07
|
Submitted by Dan Danborn, Society of Certified Senior Advisors
|
|
9/6/07
|
Submitted by Tamara K. Salmon, Investment Company Institute
|
|
8/1/06
|
Submitted by Eileen Ryan, Esq., Securities Industry Association, and Sarah Starkweather, Esq., The Bond Market Association
|
|
11/29/04
|
Submitted by Therese Squillacote, ING Financial Advisers, LLC
|
|
9/14/04
|
Submitted by Budge Collins, Collins/Bay Island Securities
|
|
12/30/03
|
Submitted by Yukako Kawata, Davis Polk & Wardwell
General Letter
|
|
10/2/03
|
Submitted by Michael D. Udoff, Securities Industry Association
|
|
5/29/03
|
Submitted by Robert C. Hacker, Esq., Kirkpatrick & Lockhart, LLP
|
|
9/30/02
|
Submitted by Susan S. Krawczyk, Esq., Sutherland Asbill & Brennan LLP
|
|
1/28/02
|
Submitted by Forrest R. Foss, T. Rowe Price Associates, Inc.
|
|
7/5/00
|
Submitted by Kathleen A. Wieland, William Blair & Company, L.L.C.
|
|
12/17/99
|
Submitted by Yoon-Young Lee, Wilmer, Cutler & Pickering
|
|
2/5/99
|
Submitted by W. Thomas Conner, National Association for Variable Annuities
|
|
7/30/98
|
Submitted by Dawn Bond, FSC Securities Corporation
|
|
6/8/98
|
Submitted by Christine A. Edwards, Morgan Stanley Dean Witter & Co.
|
|
5/11/98
|
Submitted by Sandra M. Ng, Gruntal & Co., L.L.C.
|
|
11/11/97
|
Submitted by Craig S. Tyle, Investment Company Institute
|
| |
| NASD Rule 2211 - Institutional Sales Material and Correspondence |
|
8/1/06
|
Submitted by Eileen Ryan, Esq., Securities Industry Association, and Sarah Starkweather, Esq., The Bond Market Association
|
| |
| NASD Rule 2220 - Options Communications with the Public |
|
5/1/00
|
Submitted by Leonard Mayer, Schwab Capital Markets, L.P.
|
|
3/5/99
|
Submitted by J. Craig Long, Esq., Foley & Lardner
|
| |
| NASD Rule 2310 - Recommendations to Customers (Suitability) |
|
3/17/05
|
Submitted by Tamara K. Salmon, Investment Company Institute
|
|
8/31/00
|
Submitted by Thomas E. Hellings, Securities America, Inc.
|
|
3/4/97
|
Name Not Public
|
|
1/23/97
|
Submitted by Stuart J. Kaswell, SIA
|
|
1/23/97
|
Submitted by Paul Saltzman, PSA
|
|
5/18/93
|
Name Not Public
|
|
11/13/90
|
Name Not Public
|
| |
| NASD Rule 2320 - Best Execution and Interpositioning |
|
8/19/02
|
Submitted by Howard L. Kramer, Schiff Hardin & Waite
|
|
9/5/01
|
Submitted by Donald H. Meiers, Holland & Knight, LLP
|
|
5/1/00
|
Submitted by Leonard Mayer, Schwab Capital Markets, L.P.
|
|
4/9/98
|
Submitted by Joseph McLaughlin, Brown & Wood
|
| |
| NASD Rule 2330 - Customers' Securities or Funds |
|
2/4/04
|
Submitted by Martin H. Kaplan, Esq., Gusrae, Kaplan & Bruno, PLLC
|
|
3/16/99
|
Submitted by Martin Miller, Esq., Willkie Farr & Gallagher
|
| |
| NASD Rule 2370 - Borrowing From or Lending to Customers |
|
11/7/03
|
Submitted by Harold L. Gladney
|
| |
| NASD Rule 2420 - Dealing with Non-Members |
|
12/28/07
|
Submitted by Richard Schultz, Triad Securities Corp.
|
|
6/27/01
|
Submitted by Jonathan K. Lagemann, Esq., Law Offices of Jonathan Kord Lagemann
|
|
3/8/01
|
Submitted by Jay Adams Knight, Esq., Musick, Peeler & Garrett LLP
|
|
9/27/00
|
Submitted by Kathleen A. Wieland, William Blair & Company
|
|
5/31/00
|
Submitted by Michael R. Miller, Esq., Kunkel Miller & Hament
|
|
1/18/00
|
Submitted by Gordon C. Ogden, III, Profinancial, Inc.
|
|
1/29/99
|
Submitted by Trish Stone-Damen, Investors Retirement & Management Company, Inc.
|
|
12/9/98
|
Submitted by Leslie D. Smith, Berthel Fisher & Company
|
|
12/7/98
|
Submitted by Victoria Bach-Fink, Wall Street Financial Group
|
|
9/16/98
|
Submitted by Brian C. Underwood, A.G. Edwards & Sons, Inc.
|
|
6/18/98
|
Submitted by Daniel Schloendorn, Willkie Farr & Gallagher
|
|
9/25/97
|
Submitted by David M. Katz, Sidley & Austin
|
|
8/20/97
|
Submitted by Peter D. Koffler, Twenty-First Securities Corporation
|
|
4/11/97
|
Name Not Public
|
| |
| NASD IM-2420-2 - Continuing Commissions Policy |
|
2/4/02
|
Submitted by Ted. A. Troutman, Esquire, Muir & Troutman
|
|
8/9/01
|
Submitted by Joe Tully, Commonwealth Financial Network
|
|
5/25/01
|
Name Not Public
|
|
1/21/00
|
Submitted by Peter D. Koffler, Esq., Twenty-First Securities Corporation
|
|
12/9/98
|
Submitted by Leslie D. Smith, Berthel Fisher & Company
|
|
12/23/96
|
Name Not Public
|
|
11/20/96
|
Name Not Public
|
| |
| NASD Rule 2440 - Fair Prices and Commissions |
|
1/23/01
|
Submitted by Isaac Schlesinger, Bishop, Rosen & Co., Inc.
|
|
5/2/96
|
Name Not Public
|
| |
| NASD Rule 2460 - Payments for Market Making |
|
10/6/06
|
Submitted by Alan M. Wolper, Esq., Sutherland Asbill & Brennan LLP
|
| |
| NASD Rule 2510 - Discretionary Accounts |
|
3/17/05
|
Submitted by Tamara K. Salmon, Investment Company Institute
|
|
1/26/05
|
Submitted by George T. Simon, Foley & Lardner, LLP
|
|
2/3/03
|
Submitted by Marc. A. Cohn, Metropolitan Life Insurance Company
|
| |
| NASD Rule 2710 - Corporate Financing Rule |
|
8/1/06
|
Submitted by Eileen Ryan, Esq., Securities Industry Association, and Sarah Starkweather, Esq., The Bond Market Association
|
|
6/18/98
|
Submitted by Daniel Schloendorn, Willkie Farr & Gallagher
|
| |
| NASD Rule 2711 - Research Analysts and Research Reports |
|
8/20/04
|
Submitted by Mark W. Riepe, Charles Schwab & Co., Inc.
|
| |
| NASD Rule 2720 - Distribution of Securities of Members and Affiliates - Conflicts of Interest |
|
8/1/06
|
Submitted by Eileen Ryan, Esq., Securities Industry Association, and Sarah Starkweather, Esq., The Bond Market Association
|
| |
| NASD Rule 2740 - Selling Concessions, Discounts, and Other Allowances |
|
11/24/03
|
Submitted by Dana Fleischman, Esq., Cleary, Gottlieb, Steen & Hamilton
|
|
12/9/97
|
Submitted by Lee A. Pickard, Pickard and Djinis
|
|
11/15/96
|
Name Not Public
|
|
12/22/88
|
Name Not Public
|
| |
| NASD Rule 2790 - Restrictions on the Purchase and Sale of Initial Equity Public Offerings |
|
8/6/04
|
NASD Office of General Counsel, Regulatory Policy and Oversight
|
|
6/1/04
|
Submitted by Dana G. Fleischman
|
|
2/17/04
|
Submitted by Tom Fleming, Dealogic
|
| |
| NASD Rule 2820 - Variable Contracts of an Insurance Company |
|
2/3/03
|
Submitted by Marilyn A. Sponzo, Jordan Burt
|
|
2/3/03
|
Submitted by Pamela M. Krill, Esquire, Godfrey & Kahn, S.C.
|
|
10/14/02
|
Submitted by Janet Gallo, Acacia Life Insurance Company
|
|
3/7/01
|
Name Not Public
|
|
10/12/00
|
Submitted by Eric A. Arnold, Esq., Sutherland Asbill & Brennan LLP
|
|
4/3/00
|
Submitted by Michael L. Kerley, Esq., MML Investors Services, Inc.
|
|
10/29/99
|
Submitted by Robert E. Lee, Counsel, P&A Administrative Services, Inc.
|
|
5/20/99
|
Submitted by Harley Whitfield, American Equity Capital, Inc.
|
|
3/31/99
|
Submitted by Robert B. Saginaw, Counsel, ReliaStar Financial Corp.
|
| |
| NASD Rule 2830 - Investment Company Securities |
|
9/28/06
|
Submitted by Steven K. McGinnis, Loring Ward Securities, Inc.
|
|
8/14/06
|
NASD Office of General Counsel, Regulatory Policy and Oversight
|
|
9/29/03
|
Submitted by Sarah A. Bessin, Esq., Shearman & Sterling LLP
|
|
2/3/03
|
Submitted by Pamela M. Krill, Esquire, Godfrey & Kahn, S.C.
|
|
2/3/03
|
Submitted by Suart M. Strauss, Esq., Mayer, Brown, Rowe & Maw
|
|
10/30/02
|
Submitted by Kathleen H. Moriarty, Esq., Carter, Ledyard & Milburn
|
|
6/18/01
|
Submitted by Philip J. Fina, Esq., Kirkpatrick & Lockhart LLP
|
|
3/7/01
|
Name Not Public
|
|
1/16/01
|
Submitted by Stuart M. Strauss, Esq., Mayer, Brown & Platt
|
|
11/18/99
|
Name Not Public
|
|
9/9/99
|
Submitted by Robert L. Winston, American Funds Distributors, Inc.
|
|
12/7/98
|
Submitted by Elaine S. Moshe, Gordon Altman Butowsky Weitzen
|
| |
| NASD Rule 2860 - Options |
|
2/17/99
|
Name Not Public
|
|
2/24/93
|
Name Not Public
|
| |
| NASD Rule 3010 - Supervision |
|
11/30/06
|
Submitted by Evan Charkes, Citigroup Global Markets, Inc.
|
|
11/26/01
|
Name Not Public
|
|
6/4/01
|
Submitted by Lena M. Stinson, Stanford Group Company
|
|
12/17/99
|
Submitted by Yoon-Young Lee, Wilmer, Cutler & Pickering
|
|
3/17/98
|
Submitted by Franklin I. Ogele, Esq., Singer Zamansky LLP
|
|
11/26/97
|
Submitted by Laura Moret, American Express Financial Corporation
|
|
4/11/97
|
Name Not Public
|
|
8/13/96
|
Name Not Public
|
|
8/9/96
|
Name Not Public
|
| |
| NASD Rule 3030 - Outside Business Activities of an Association Person |
|
3/1/02
|
Submitted by Frank Almeida, Quality of Life Settlements
|
|
12/6/01
|
Submitted by Sheryl Anne Zuckerman, Esq., Singer Frumento LLP
|
|
12/23/99
|
Submitted by R. Bruce Hughes, Access Mortgage Services, Inc.
|
|
10/27/97
|
Submitted by Paul D. Coury, The Coury Financial Group
|
|
7/30/97
|
Submitted by Webster E. Janssen, Janssen Financial Services
|
|
9/15/94
|
Name Not Public
|
| |
| NASD Rule 3040 - Private Securities Transactions of an Associated Person |
|
11/4/02
|
Submitted by Donna B. Lawson, First Allied Securities, Inc.
|
|
10/27/97
|
Submitted by Paul D. Coury, The Coury Financial Group
|
|
8/4/97
|
Name Not Public
|
|
12/16/96
|
Name Not Public
|
|
7/23/96
|
Name Not Public
|
|
9/27/94
|
Name Not Public
|
|
8/5/94
|
Name Not Public
|
| |
| NASD Rule 3060 - Influencing or Rewarding Employees of Others |
|
12/17/07
|
Submitted by Amal Aly, SIFMA (Reasonable and Customary Bereavement Gifts)
|
|
3/15/01
|
Submitted by Charles Wiegert, NFP Securities
|
|
6/24/99
|
Submitted by Henry H. Hopkins and Sarah McCafferty, T. Rowe Price Investment Services, Inc.
|
| |
| NASD Rule 3070 - Reporting Requirements |
|
1/2/02
|
Name Not Public
|
|
5/28/96
|
Name Not Public
|
|
5/28/96
|
Name Not Public
|
| |
| NASD Rule 3110 - Books and Records |
|
3/17/05
|
Submitted by Tamara K. Salmon, Investment Company Institute
|
|
6/4/02
|
Submitted by Selwyn Notelovitz, Global Compliance
|
|
7/5/01
|
Submitted by Jeffrey W. Kilduff, Esq., O'Melveny & Myers, LLP
|
|
11/27/00
|
Submitted by Angela Coronado, Brecek & Young Advisors, Inc.
|
|
8/4/00
|
Submitted by Alan Feldstein, Esq., Development Corporation for Israel
|
|
7/24/00
|
Submitted by Fiona Kaufman, Esq., SVB Securities, Inc.
|
|
6/15/00
|
Submitted by Steven F. Gatti, Esq., Clifford, Chance, Rogers & Wells
|
|
10/26/99
|
Submitted by James A. Ricketts, Ameritrade, Inc.
|
|
11/26/97
|
Submitted by Laura Moret, American Express Financial Corporation
|
|
11/1/95
|
Name Not Public
|
| |
| NASD IM-3310 - Manipulative and Deceptive Quotations |
|
8/29/97
|
Submitted by Lloyd H. Feller, Morgan, Lewis & Bockius
|
| |
| NASD Rule 3220 - Adjustment of Open Orders |
|
5/15/01
|
Submitted by Charles Freund, Brown Brothers Harriman
|
| |
| NASD Rule 3230 - Clearing Agreements |
|
8/7/01
|
Submitted by Bob E. Lehman, Esq., Lehman & Eilen LLP
|
|
7/23/99
|
Name Not Public
|
| |
| NASD Rule 3350 - Short Sale Rule |
|
2/8/99
|
Submitted by Roger D. Blanc, Esq., Willkie Farr & Gallagher
|
| |
| NASD Rule 3370 - Prompt Receipt and Delivery of Securities |
|
5/25/01
|
Name Not Public
|
|
4/27/01
|
Name Not Public
|
|
6/20/00
|
Submitted by Robinson Markel, Esq., Rosenman & Colin, LLP
|
|
1/18/00
|
Submitted by Michael T. Dorsey, Knight Securities, L.P.
|
|
9/18/96
|
Name Not Public
|
|
7/26/95
|
Submitted by Richard Lewandowski, The Options Exchange
|
