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 Type Related Rule / Topicsort descending
Jan 23, 2001 Interpretive Letter to Isaac Schlesinger, Bishop, Rosen & Co., Inc. Conduct Rules NASD Rule 2440 - Fair Prices and Commissions
May 2, 1996 Interpretive Letter to Name Not Public 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 15, 2008 Letter from FINRA Office of General Counsel, May 15, 2008 Conduct Rules NASD Rule 2510 - Discretionary Accounts
Feb 3, 2003 Interpretive Letter to Marc. A. Cohn, Metropolitan Life Insurance Company Conduct Rules NASD Rule 2510 - Discretionary Accounts
Jan 26, 2005 Interpretive Letter to George T. Simon, Foley & Lardner, LLP Conduct Rules NASD Rule 2510 - Discretionary Accounts
Mar 16, 2005 Interpretive Letter to Tamara K. Salmon, Investment Company Institute Conduct Rules NASD Rule 2510 - Discretionary Accounts
Jun 18, 1998 Interpretive Letter to Daniel Schloendorn, Willkie Farr & Gallagher Conduct Rules NASD Rule 2710 - Corporate Financing Rule
Aug 20, 2004 Interpretive Letter to Mark W. Riepe, Charles Schwab & Co., Inc. Conduct Rules NASD Rule 2711 - Research Analysts and Research Reports
Feb 8, 2013 Interpretive Letter to Amy Natterson Kroll, Bingham McCutchen LLP Conduct Rules NASD Rule 2711 - Research Analysts and Research Reports
Apr 28, 2014 Interpretive Letter to Russell D. Sacks, Shearman & Sterling LLP Conduct Rules NASD Rule 2711 - Research Analysts and Research Reports
Nov 24, 2003 Interpretive Letter to Dana Fleischman, Esq., Cleary, Gottlieb, Steen & Hamilton Conduct Rules NASD Rule 2740 - Selling Concessions, Discounts, and Other Allowances
Dec 9, 1997 Interpretive Letter to Lee A. Pickard, Pickard and Djinis Conduct Rules NASD Rule 2740 - Selling Concessions, Discounts, and Other Allowances
Nov 15, 1996 Interpretive Letter to Name Not Public Conduct Rules NASD Rule 2740 - Selling Concessions, Discounts, and Other Allowances
Dec 22, 1988 Interpretive Letter to Name Not Public Conduct Rules NASD Rule 2740 - Selling Concessions, Discounts, and Other Allowances
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
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
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
Feb 3, 2003 Interpretive Letter to Marilyn A. Sponzo, Jordan Burt Conduct Rules NASD Rule 2820 - Variable Contracts of an Insurance Company
Feb 3, 2003 Interpretive Letter to Pamela M. Krill, Esquire, Godfrey & Kahn, S.C. Conduct Rules NASD Rule 2820 - Variable Contracts of an Insurance Company
Oct 14, 2002 Interpretive Letter to Janet Gallo, Acacia Life Insurance Company Conduct Rules NASD Rule 2820 - Variable Contracts of an Insurance Company
Oct 29, 1999 Interpretive Letter to Robert E. Lee, Counsel, P&A Administrative Services, Inc. Conduct Rules NASD Rule 2820 - Variable Contracts of an Insurance Company
Mar 7, 2001 Interpretive Letter to Name Not Public Conduct Rules NASD Rule 2820 - Variable Contracts of an Insurance Company
Oct 12, 2000 Interpretive Letter to Eric A. Arnold, Esq., Sutherland Asbill & Brennan LLP Conduct Rules NASD Rule 2820 - Variable Contracts of an Insurance Company
Apr 3, 2000 Interpretive Letter to Michael L. Kerley, Esq., MML Investors Services, Inc. Conduct Rules NASD Rule 2820 - Variable Contracts of an Insurance Company

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