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
May 25, 2001 Interpretive Letter to Name Not Public Conduct Rules NASD Rule 3370 - Prompt Receipt and Delivery of Securities
Nov 26, 1997 Interpretive Letter to Laura Moret, American Express Financial Corporation Conduct Rules NASD Rule 3010 - Supervision
May 20, 1999 Interpretive Letter to Harley Whitfield, American Equity Capital, Inc. Conduct Rules NASD Rule 2820 - Variable Contracts of an Insurance Company
Feb 8, 2013 Interpretive Letter to Amy Natterson Kroll, Bingham McCutchen LLP Conduct Rules NASD Rule 2711 - Research Analysts and Research Reports
Jan 23, 2001 Interpretive Letter to Isaac Schlesinger, Bishop, Rosen & Co., Inc. Conduct Rules NASD Rule 2440 - Fair Prices and Commissions
Oct 6, 2006 Interpretive Letter to Alan M. Wolper, Esq., Sutherland Asbill & Brennan LLP Conduct Rules NASD Rule 2460 - Payments for Market Making
May 31, 2000 Interpretive Letter to Michael R. Miller, Esq., Kunkel Miller & Hament Conduct Rules NASD Rule 2420 - Dealing with Non-Members
Mar 14, 2001 Interpretive Letter to Charles Wiegert, NFP Securities Conduct Rules NASD Rule 3060 - Influencing or Rewarding Employees of Others
Aug 20, 2004 Interpretive Letter to Mark W. Riepe, Charles Schwab & Co., Inc. Conduct Rules NASD Rule 2711 - Research Analysts and Research Reports
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
Jun 1, 2004 Interpretive Letter to Dana G. Fleischman Conduct Rules NASD Rule 2790 - Restrictions on the Purchase and Sale of Initial Equity Public Offerings
Apr 27, 2001 Interpretive Letter to Name Not Public Conduct Rules NASD Rule 3370 - Prompt Receipt and Delivery of Securities
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
Mar 30, 1999 Interpretive Letter to Robert B. Saginaw, Counsel, ReliaStar Financial Corp. Conduct Rules NASD Rule 2820 - Variable Contracts of an Insurance Company
Apr 22, 2013 Interpretive Letter to Bradley J. Swenson, ALPS Distributors, Inc. Conduct Rules FINRA Rule 2210 - Communications with the Public
May 2, 1996 Interpretive Letter to Name Not Public Conduct Rules NASD Rule 2440 - Fair Prices and Commissions
Nov 30, 2006 Interpretive Letter to Evan Charkes, Citigroup Global Markets, Inc. Conduct Rules NASD Rule 3010 - Supervision
Jan 18, 2000 Interpretive Letter to Gordon C. Ogden, III, Profinancial, Inc. 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
Aug 6, 2004 NASD Office of General Counsel, Regulatory Policy and Oversight Conduct Rules NASD Rule 2790 - Restrictions on the Purchase and Sale of Initial Equity Public Offerings
Jun 20, 2000 Interpretive Letter to Robinson Markel, Esq., Rosenman & Colin, LLP Conduct Rules NASD Rule 3370 - Prompt Receipt and Delivery of Securities
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

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