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
Feb 3, 2003 Interpretive Letter to Suart M. Strauss, Esq., Mayer, Brown, Rowe & Maw Conduct Rules NASD Rule 2830 - Investment Company Securities
Jan 18, 2000 Interpretive Letter to Michael T. Dorsey, Knight Securities, L.P. Conduct Rules NASD Rule 3370 - Prompt Receipt and Delivery of Securities
Jun 18, 1998 Interpretive Letter to Daniel Schloendorn, Willkie Farr & Gallagher Conduct Rules NASD Rule 2710 - Corporate Financing Rule
Feb 5, 2013 Interpretive Letter to S. Kendrick Dunn, Pacific Select Distributors, Inc. Conduct Rules NASD Rule 3010 - Supervision
Jul 3, 1997 Interpretive Letter to Name Not Public Conduct Rules NASD IM-2110-2 - Trading Ahead of Customer Limit Order
Dec 7, 1998 Interpretive Letter to Victoria Bach-Fink, Wall Street Financial Group Conduct Rules NASD Rule 2420 - Dealing with Non-Members
Sep 28, 2006 Interpretive Letter to Steven K. McGinnis, Loring Ward Securities, Inc. Conduct Rules NASD Rule 2830 - Investment Company Securities
May 28, 1996 Interpretive Letter to Name Not Public Conduct Rules NASD Rule 3070 - Reporting Requirements
Aug 31, 2000 Interpretive Letter to Thomas E. Hellings, Securities America, Inc. Conduct Rules NASD Rule 2310 - Recommendations to Customers (Suitability)
Sep 14, 2004 Interpretive Letter to Budge Collins, Collins/Bay Island Securities Conduct Rules NASD Rule 2210 - Communications with the Public
Aug 9, 1996 Interpretive Letter to Name Not Public Conduct Rules NASD Rule 3010 - Supervision
Oct 29, 2002 Interpretive Letter to Kathleen H. Moriarty, Esq., Carter, Ledyard & Milburn Conduct Rules NASD Rule 2830 - Investment Company Securities
Sep 18, 1996 Interpretive Letter to Name Not Public Conduct Rules NASD Rule 3370 - Prompt Receipt and Delivery of Securities
Nov 24, 2003 Interpretive Letter to Dana Fleischman, Esq., Cleary, Gottlieb, Steen & Hamilton Conduct Rules NASD Rule 2740 - Selling Concessions, Discounts, and Other Allowances
Feb 8, 2013 Interpretive Letter to Amy Natterson Kroll, Bingham McCutchen LLP Conduct Rules NASD Rule 2711 - Research Analysts and Research Reports
Aug 29, 1997 Interpretive Letter to Lloyd H. Feller, Morgan, Lewis & Bockius Conduct Rules NASD Rule 2120 - Use of Manipulative, Deceptive, or Other Fraudulent Devices
Sep 16, 1998 Interpretive Letter to Brian C. Underwood, A.G. Edwards & Sons, Inc. Conduct Rules NASD Rule 2420 - Dealing with Non-Members
Oct 6, 2006 Interpretive Letter to Alan M. Wolper, Esq., Sutherland Asbill & Brennan LLP Conduct Rules NASD Rule 2460 - Payments for Market Making
May 28, 1996 Interpretive Letter to Name Not Public Conduct Rules NASD Rule 3070 - Reporting Requirements
Mar 4, 1997 Interpretive Letter to Name Not Public Conduct Rules NASD Rule 2310 - Recommendations to Customers (Suitability)
Aug 20, 2004 Interpretive Letter to Mark W. Riepe, Charles Schwab & Co., Inc. Conduct Rules NASD Rule 2711 - Research Analysts and Research Reports
Mar 1, 2002 Interpretive Letter to Frank Almeida, Quality of Life Settlements Conduct Rules NASD Rule 3030 - Outside Business Activities of an Association Person
Jun 18, 2001 Interpretive Letter to Philip J. Fina, Esq., Kirkpatrick & Lockhart LLP Conduct Rules NASD Rule 2830 - Investment Company Securities
Jul 26, 1995 Interpretive Letter to Richard Lewandowski, The Options Exchange Conduct Rules NASD Rule 3370 - Prompt Receipt and Delivery of Securities
Dec 9, 1997 Interpretive Letter to Lee A. Pickard, Pickard and Djinis Conduct Rules NASD Rule 2740 - Selling Concessions, Discounts, and Other Allowances

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