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 14, 2006 NASD Office of General Counsel, Regulatory Policy and Oversight Conduct Rules NASD Rule 2830 - Investment Company Securities
Mar 7, 2001 Interpretive Letter to Name Not Public Conduct Rules NASD Rule 2830 - Investment Company Securities
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
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
Apr 27, 2001 Interpretive Letter to Name Not Public Conduct Rules NASD Rule 3370 - Prompt Receipt and Delivery of Securities
Apr 16, 2018 Interpretive letter to Joan E. Boros, Esq., Stradley Ronon Stevens & Young, LLP Conduct Rules FINRA Rule 2210 - Communications with the Public
Feb 4, 2002 Interpretive Letter to Ted. A. Troutman, Esquire, Muir & Troutman Conduct Rules NASD IM-2420-2 - Continuing Commissions Policy
Nov 27, 2012 Interpretive Letter to Name Not Public Conduct Rules NASD IM-2420-2 - Continuing Commissions Policy
Apr 9, 1998 Interpretive Letter to Joseph McLaughlin, Brown & Wood Conduct Rules NASD Rule 2320 - Best Execution and Interpositioning
Sep 15, 1994 Interpretive Letter to Name Not Public Conduct Rules NASD Rule 3030 - Outside Business Activities of an Association Person
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
Nov 18, 1999 Interpretive Letter to Name Not Public Conduct Rules NASD Rule 2830 - Investment Company 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 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
Jun 20, 2000 Interpretive Letter to Robinson Markel, Esq., Rosenman & Colin, LLP Conduct Rules NASD Rule 3370 - Prompt Receipt and Delivery of Securities
Jan 31, 2019 Interpretive letter to Meredith F. Henning, Foreside Conduct Rules FINRA Rule 2210 - Communications with the Public
Aug 9, 2001 Interpretive Letter to Joe Tully, Commonwealth Financial Network Conduct Rules NASD IM-2420-2 - Continuing Commissions Policy
Apr 16, 1997 Interpretive Letter to Name Not Public Conduct Rules NASD IM-2110-2 - Trading Ahead of Customer Limit Order
Feb 4, 2004 Interpretive Letter to Martin H. Kaplan, Esq., Gusrae, Kaplan & Bruno, PLLC Conduct Rules NASD Rule 2330 - Customers' Securities or Funds
Nov 4, 2002 Interpretive Letter to Donna B. Lawson, First Allied Securities, Inc. Conduct Rules NASD Rule 3040 - Private Securities Transactions of an Associated Person
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 9, 1999 Interpretive Letter to Robert L. Winston, American Funds Distributors, Inc. Conduct Rules NASD Rule 2830 - Investment Company Securities
Sep 30, 2002 Interpretive Letter to Susan S. Krawczyk, Esq., Sutherland Asbill & Brennan LLP Conduct Rules NASD Rule 2210 - Communications with the Public
Oct 14, 2002 Interpretive Letter to Janet Gallo, Acacia Life Insurance Company Conduct Rules NASD Rule 2820 - Variable Contracts of an Insurance Company

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