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 20, 1997 Interpretive Letter to Peter D. Koffler, Twenty-First Securities Corporation Conduct Rules NASD Rule 2420 - Dealing with Non-Members
Feb 8, 1999 Interpretive Letter to Roger D. Blanc, Esq., Willkie Farr & Gallagher Conduct Rules NASD Rule 3350 - Short Sale Rule
Aug 15, 2006 NASD Office of General Counsel, Regulatory Policy and Oversight Conduct Rules NASD Rule 2110 - Standards of Commercial Honor and Principles of Trade
Aug 19, 2002 Interpretive Letter to Howard L. Kramer, Schiff Hardin & Waite Conduct Rules NASD Rule 2320 - Best Execution and Interpositioning
Oct 26, 1997 Interpretive Letter to Paul D. Coury, The Coury Financial Group Conduct Rules NASD Rule 3030 - Outside Business Activities of an Association Person
May 29, 2003 Interpretive Letter to Robert C. Hacker, Esq., Kirkpatrick & Lockhart, LLP Conduct Rules NASD Rule 2210 - Communications with the Public
Nov 26, 1997 Interpretive Letter to Laura Moret, American Express Financial Corporation Conduct Rules NASD Rule 3110 - Books and Records
Dec 7, 1998 Interpretive Letter to Elaine S. Moshe, Gordon Altman Butowsky Weitzen Conduct Rules NASD Rule 2830 - Investment Company Securities
Jun 12, 2017 Interpretive Letter to Clair Pagnano, K&L Gates LLP Conduct Rules FINRA Rule 2210 - Communications with the Public
Dec 22, 1988 Interpretive Letter to Name Not Public Conduct Rules NASD Rule 2740 - Selling Concessions, Discounts, and Other Allowances
Mar 18, 2001 Interpretive Letter to Klia Ververidis, Esq., AssetStream Corporation Conduct Rules NASD Rule 2110 - Standards of Commercial Honor and Principles of Trade
Apr 11, 1997 Interpretive Letter to Name Not Public Conduct Rules NASD Rule 2420 - Dealing with Non-Members
Aug 7, 2001 Interpretive Letter to Bob E. Lehman, Esq., Lehman & Eilen LLP Conduct Rules NASD Rule 3230 - Clearing Agreements
Jul 23, 1999 Interpretive Letter to Name Not Public Conduct Rules NASD Rule 3230 - Clearing Agreements
Aug 14, 2006 NASD Office of General Counsel, Regulatory Policy and Oversight Conduct Rules NASD Rule 2830 - Investment Company Securities
Sep 5, 2001 Interpretive Letter to Donald H. Meiers, Holland & Knight, LLP Conduct Rules NASD Rule 2320 - Best Execution and Interpositioning
Jul 30, 1997 Interpretive Letter to Webster E. Janssen, Janssen Financial Services Conduct Rules NASD Rule 3030 - Outside Business Activities of an Association Person
Jan 28, 2002 Interpretive Letter to Forrest R. Foss, T. Rowe Price Associates, Inc. Conduct Rules NASD Rule 2210 - Communications with the Public
Oct 20, 2004 Interpretive Letter to Barry Harris, Banc of America Investment Services, Inc. (Use of Negative Response Letters) Conduct Rules NASD Rule 2110 - Standards of Commercial Honor and Principles of Trade
Mar 7, 2001 Interpretive Letter to Name Not Public Conduct Rules NASD Rule 2830 - Investment Company Securities
Dec 11, 2017 Interpretive Letter to Lawrence Cohen, Gordon Rees Scully Mansukhani, LLP Conduct Rules FINRA Rule 5130 - Restrictions on the Purchase and Sale of Initial Equity Public Offerings
Feb 17, 2004 Interpretive Letter to Tom Fleming, Dealogic Conduct Rules NASD Rule 2790 - Restrictions on the Purchase and Sale of Initial Equity Public Offerings
Dec 22, 2000 Interpretive Letter to Barbara A. Mallon, Esq., Mallon & Johnson, P.C. Conduct Rules NASD Rule 2110 - Standards of Commercial Honor and Principles of Trade
Dec 9, 1998 Interpretive Letter to Leslie D. Smith, Berthel Fisher & Company Conduct Rules NASD Rule 2420 - Dealing with Non-Members
May 15, 2001 Interpretive Letter to Charles Freund, Brown Brothers Harriman Conduct Rules NASD Rule 3220 - Adjustment of Open Orders

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