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 ascending Related Rule / Topic
May 29, 2003 Interpretive Letter to Robert C. Hacker, Esq., Kirkpatrick & Lockhart, LLP Conduct Rules NASD Rule 2210 - Communications with the Public
Dec 7, 1998 Interpretive Letter to Victoria Bach-Fink, Wall Street Financial Group Conduct Rules NASD Rule 2420 - Dealing with Non-Members
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)
Aug 9, 1996 Interpretive Letter to Name Not Public Conduct Rules NASD Rule 3010 - Supervision
Feb 5, 2013 Interpretive Letter to S. Kendrick Dunn, Pacific Select Distributors, Inc. Conduct Rules NASD Rule 3010 - Supervision
Mar 18, 2001 Interpretive Letter to Klia Ververidis, Esq., AssetStream Corporation 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
Sep 28, 2006 Interpretive Letter to Steven K. McGinnis, Loring Ward Securities, Inc. Conduct Rules NASD Rule 2830 - Investment Company Securities
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
Nov 24, 2003 Interpretive Letter to Dana Fleischman, Esq., Cleary, Gottlieb, Steen & Hamilton Conduct Rules NASD Rule 2740 - Selling Concessions, Discounts, and Other Allowances
Aug 20, 2004 Interpretive Letter to Mark W. Riepe, Charles Schwab & Co., Inc. Conduct Rules NASD Rule 2711 - Research Analysts and Research Reports
Jan 28, 2002 Interpretive Letter to Forrest R. Foss, T. Rowe Price Associates, Inc. Conduct Rules NASD Rule 2210 - Communications with the Public
Sep 16, 1998 Interpretive Letter to Brian C. Underwood, A.G. Edwards & Sons, Inc. Conduct Rules NASD Rule 2420 - Dealing with Non-Members
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)
Mar 1, 2002 Interpretive Letter to Frank Almeida, Quality of Life Settlements Conduct Rules NASD Rule 3030 - Outside Business Activities of an Association Person
Feb 8, 2013 Interpretive Letter to Amy Natterson Kroll, Bingham McCutchen LLP Conduct Rules NASD Rule 2711 - Research Analysts and Research Reports
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
Oct 29, 2002 Interpretive Letter to Kathleen H. Moriarty, Esq., Carter, Ledyard & Milburn Conduct Rules NASD Rule 2830 - Investment Company Securities
Oct 6, 2006 Interpretive Letter to Alan M. Wolper, Esq., Sutherland Asbill & Brennan LLP Conduct Rules NASD Rule 2460 - Payments for Market Making
May 15, 2001 Interpretive Letter to Charles Freund, Brown Brothers Harriman Conduct Rules NASD Rule 3220 - Adjustment of Open Orders
Dec 9, 1997 Interpretive Letter to Lee A. Pickard, Pickard and Djinis Conduct Rules NASD Rule 2740 - Selling Concessions, Discounts, and Other Allowances
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

Pages