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 2, 1996 Interpretive Letter to Name Not Public Conduct Rules NASD Rule 2440 - Fair Prices and Commissions
Apr 16, 2018 Interpretive letter to Joan E. Boros, Esq., Stradley Ronon Stevens & Young, LLP Conduct Rules FINRA Rule 2210 - Communications with the Public
Jan 18, 2000 Interpretive Letter to Gordon C. Ogden, III, Profinancial, Inc. Conduct Rules NASD Rule 2420 - Dealing with Non-Members
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
Nov 27, 2012 Interpretive Letter to Name Not Public Conduct Rules NASD IM-2420-2 - Continuing Commissions Policy
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
Jun 2, 2006 Interpretive Letter to Michael R. Trocchio, Esq., Bingham McCutchen LLP Conduct Rules NASD Rule 2110 - Standards of Commercial Honor and Principles of Trade
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 27, 2001 Interpretive Letter to Name Not Public Conduct Rules NASD Rule 3370 - Prompt Receipt and Delivery of Securities
Nov 8, 2004 NASD Office of General Counsel, Regulatory Policy and Oversight Conduct Rules NASD Rule 2110 - Standards of Commercial Honor and Principles of Trade
Feb 3, 2003 Interpretive Letter to Marc. A. Cohn, Metropolitan Life Insurance Company Conduct Rules NASD Rule 2510 - Discretionary Accounts
Apr 16, 1997 Interpretive Letter to Name Not Public Conduct Rules NASD IM-2110-2 - Trading Ahead of Customer Limit Order
Jan 31, 2019 Interpretive letter to Meredith F. Henning, Foreside Conduct Rules FINRA 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
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)
Aug 13, 1996 Interpretive Letter to Name Not Public Conduct Rules NASD Rule 3010 - Supervision
Aug 1, 2006 Interpretive Letter to Eileen Ryan, Esq., Securities Industry Association, and Sarah Starkweather, Esq., The Bond Market Association Conduct Rules NASD Rule 2211 - Institutional Sales Material and Correspondence
Sep 29, 2003 Interpretive Letter to Sarah A. Bessin, Esq., Shearman & Sterling LLP Conduct Rules NASD Rule 2830 - Investment Company Securities
Jun 20, 2000 Interpretive Letter to Robinson Markel, Esq., Rosenman & Colin, LLP Conduct Rules NASD Rule 3370 - Prompt Receipt and Delivery of Securities
Sep 30, 2002 Interpretive Letter to Susan S. Krawczyk, Esq., Sutherland Asbill & Brennan LLP Conduct Rules NASD Rule 2210 - Communications with the Public
Sep 14, 2004 Interpretive Letter to Budge Collins, Collins/Bay Island Securities Conduct Rules NASD Rule 2210 - Communications with the Public
Jun 18, 1998 Interpretive Letter to Daniel Schloendorn, Willkie Farr & Gallagher Conduct Rules NASD Rule 2710 - Corporate Financing Rule
Jul 3, 1997 Interpretive Letter to Name Not Public Conduct Rules NASD IM-2110-2 - Trading Ahead of Customer Limit Order

Pages