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
Jan 18, 2000 Interpretive Letter to Gordon C. Ogden, III, Profinancial, Inc. Conduct Rules NASD Rule 2420 - Dealing with Non-Members
Jan 26, 2005 Interpretive Letter to George T. Simon, Foley & Lardner, LLP Conduct Rules NASD Rule 2510 - Discretionary Accounts
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
May 18, 1993 Interpretive Letter to Name Not Public Conduct Rules NASD Rule 2310 - Recommendations to Customers (Suitability)
Oct 31, 1995 Interpretive Letter to Name Not Public Conduct Rules NASD Rule 3110 - Books and Records
Apr 11, 1997 Interpretive Letter to Name Not Public Conduct Rules NASD Rule 3010 - Supervision
May 1, 2003 Interpretive Letter to Michael D. Wolk, Esq., Foley and Lardner (Use of Negative Response Letters) Conduct Rules NASD Rule 2110 - Standards of Commercial Honor and Principles of Trade
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
Aug 29, 1997 Interpretive Letter to Lloyd H. Feller, Morgan, Lewis & Bockius Conduct Rules NASD IM-3310 - Manipulative and Deceptive Quotations
Feb 3, 2003 Interpretive Letter to Marc. A. Cohn, Metropolitan Life Insurance Company Conduct Rules NASD Rule 2510 - Discretionary Accounts
Dec 28, 2007 Interpretive Letter to Richard Schultz, Triad Securities Corp. Conduct Rules NASD Rule 2420 - Dealing with Non-Members
Feb 5, 1999 Interpretive Letter to W. Thomas Conner, National Association for Variable Annuities Conduct Rules NASD Rule 2210 - Communications with the Public
Jan 29, 1999 Interpretive Letter to Trish Stone-Damen, Investors Retirement & Management Company, Inc. Conduct Rules NASD Rule 2420 - Dealing with Non-Members
Nov 29, 2004 Interpretive Letter to Therese Squillacote, ING Financial Advisers, LLC Conduct Rules NASD Rule 2210 - Communications with the Public
Jan 2, 2002 Interpretive Letter to Name Not Public Conduct Rules NASD Rule 3070 - Reporting Requirements
Nov 13, 1990 Interpretive Letter to Name Not Public Conduct Rules NASD Rule 2310 - Recommendations to Customers (Suitability)
Jul 5, 2001 Interpretive Letter to Jeffrey W. Kilduff, Esq., O'Melveny & Myers, LLP Conduct Rules NASD Rule 3110 - Books and Records
Aug 13, 1996 Interpretive Letter to Name Not Public Conduct Rules NASD Rule 3010 - Supervision
Feb 3, 2003 Interpretive Letter to Doug Wright, The Investment Center, Inc. (Use of Negative Response Letters) Conduct Rules NASD Rule 2110 - Standards of Commercial Honor and Principles of Trade
Feb 3, 2003 Interpretive Letter to Marion A. Kashan, London Pacific Securities, Inc. (Use of Negative Response Letters) Conduct Rules NASD Rule 2110 - Standards of Commercial Honor and Principles of Trade
Feb 3, 2003 Interpretive Letter to Suart M. Strauss, Esq., Mayer, Brown, Rowe & Maw Conduct Rules NASD Rule 2830 - Investment Company Securities
May 12, 2015 Interpretive Letter to Edward P. Macdonald, Hartford Funds Distributors, LLC Conduct Rules FINRA Rule 2210 - Communications with the Public
Jun 4, 2002 Interpretive Letter to Selwyn Notelovitz, Global Compliance Conduct Rules NASD Rule 3110 - Books and Records
Jun 18, 1998 Interpretive Letter to Daniel Schloendorn, Willkie Farr & Gallagher Conduct Rules NASD Rule 2710 - Corporate Financing Rule

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