Interpretive Letters

All interpretive positions are staff position, unless otherwise indicated. Staff-issued interpretive letters express staff views and opinions only and are not binding on FINRA and its Board; any representation to the contrary is expressly disclaimed.

The letters provide general guidance on the staff's views as to the application of particular NASD rules under specific circumstance.

Members, associated persons, and their counsel should consider seeking further guidance regarding their own unique circumstances.

Date Title Typesort descending Related Rule / Topic
Aug 7, 2001 Interpretive Letter to Name Not Public By-Laws Article V, Section 2 - Application for Registration
Sep 28, 1999 Interpretive Letter to Gerald L. Fishman, Esq., Wolin & Rosen By-Laws Article III, Section 4 - Definition of Disqualification
Sep 28, 2000 Interpretive Letter to Leslie U. Harris, East/West Securities Co. By-Laws Article IV, Section 2 - Similarity of Membership Names
Mar 30, 1999 Interpretive Letter to Robert B. Saginaw, Counsel, ReliaStar Financial Corp. Conduct Rules NASD Rule 2820 - Variable Contracts of an Insurance Company
May 2, 1996 Interpretive Letter to Name Not Public Conduct Rules NASD Rule 2440 - Fair Prices and Commissions
Apr 27, 2001 Interpretive Letter to Name Not Public Conduct Rules NASD Rule 3370 - Prompt Receipt and Delivery of Securities
Jan 18, 2000 Interpretive Letter to Gordon C. Ogden, III, Profinancial, Inc. Conduct Rules NASD Rule 2420 - Dealing with Non-Members
Jun 24, 1999 Interpretive Letter to Henry H. Hopkins and Sarah McCafferty, T. Rowe Price Investment Services, Inc. Conduct Rules NASD Rule 3060 - Influencing or Rewarding Employees of Others
Jan 26, 2005 Interpretive Letter to George T. Simon, Foley & Lardner, LLP Conduct Rules NASD Rule 2510 - Discretionary Accounts
May 18, 1993 Interpretive Letter to Name Not Public Conduct Rules NASD Rule 2310 - Recommendations to Customers (Suitability)
Apr 11, 1997 Interpretive Letter to Name Not Public Conduct Rules NASD Rule 3010 - Supervision
Oct 31, 1995 Interpretive Letter to Name Not Public Conduct Rules NASD Rule 3110 - Books and Records
Sep 29, 2003 Interpretive Letter to Sarah A. Bessin, Esq., Shearman & Sterling LLP Conduct Rules NASD Rule 2830 - Investment Company Securities
Feb 20, 2015 Interpretive Letter to Gregory J. Nowak, Pepper Hamilton LLP Conduct Rules FINRA Rule 5130 - Restrictions on the Purchase and Sale of Initial Equity Public Offerings
Feb 3, 2003 Interpretive Letter to Marc. A. Cohn, Metropolitan Life Insurance Company Conduct Rules NASD Rule 2510 - Discretionary Accounts
Jun 20, 2000 Interpretive Letter to Robinson Markel, Esq., Rosenman & Colin, LLP Conduct Rules NASD Rule 3370 - Prompt Receipt and Delivery of Securities
Dec 28, 2007 Interpretive Letter to Richard Schultz, Triad Securities Corp. Conduct Rules NASD Rule 2420 - Dealing with Non-Members
Jan 29, 1999 Interpretive Letter to Trish Stone-Damen, Investors Retirement & Management Company, Inc. Conduct Rules NASD Rule 2420 - Dealing with Non-Members
Jan 2, 2002 Interpretive Letter to Name Not Public Conduct Rules NASD Rule 3070 - Reporting Requirements
Apr 16, 1997 Interpretive Letter to Name Not Public Conduct Rules NASD IM-2110-2 - Trading Ahead of Customer Limit Order
Nov 29, 2004 Interpretive Letter to Therese Squillacote, ING Financial Advisers, LLC Conduct Rules NASD Rule 2210 - Communications with the Public
Nov 13, 1990 Interpretive Letter to Name Not Public Conduct Rules NASD Rule 2310 - Recommendations to Customers (Suitability)
Aug 13, 1996 Interpretive Letter to Name Not Public Conduct Rules NASD Rule 3010 - Supervision
Jul 5, 2001 Interpretive Letter to Jeffrey W. Kilduff, Esq., O'Melveny & Myers, LLP Conduct Rules NASD Rule 3110 - Books and Records
Nov 27, 2000 Interpretive Letter to Angela Coronado, Brecek & Young Advisors, Inc. Conduct Rules NASD Rule 3110 - Books and Records

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