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.

Datesort descending Title Type Related Rule / Topic
Mar 1, 2002 Interpretive Letter to Frank Almeida, Quality of Life Settlements Conduct Rules NASD Rule 3030 - Outside Business Activities of an Association Person
Jun 4, 2002 Interpretive Letter to Selwyn Notelovitz, Global Compliance Conduct Rules NASD Rule 3110 - Books and Records
Aug 19, 2002 Interpretive Letter to Howard L. Kramer, Schiff Hardin & Waite Conduct Rules NASD Rule 2320 - Best Execution and Interpositioning
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
Oct 29, 2002 Interpretive Letter to Kathleen H. Moriarty, Esq., Carter, Ledyard & Milburn Conduct Rules NASD Rule 2830 - Investment Company Securities
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
Nov 13, 2002 Interpretive Letter to Dennis C. Hensley, Sidley Austin Brown and Wood LLP Marketplace Rules NASD Rule 6200 Series - Trade Reporting and Compliance Engine (TRACE)
Nov 13, 2002 Interpretive Letter to Danny Ho, Commerzbank Securities Marketplace Rules NASD Rule 6200 Series - Trade Reporting and Compliance Engine (TRACE)
Dec 12, 2002 Interpretive Letter to R. Cromwell Coulson, Pink Sheets LLC 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 Doug Wright, The Investment Center, Inc. (Use of Negative Response Letters) Conduct Rules NASD Rule 2110 - Standards of Commercial Honor and Principles of Trade
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
Feb 3, 2003 Interpretive Letter to Marion A. Kashan, London Pacific Securities, Inc. (Use of Negative Response Letters) Conduct Rules NASD Rule 2110 - Standards of Commercial Honor and Principles of Trade
Feb 3, 2003 Interpretive Letter to Pamela M. Krill, Esquire, Godfrey & Kahn, S.C. Conduct Rules NASD Rule 2830 - Investment Company Securities
Feb 3, 2003 Interpretive Letter to Marc. A. Cohn, Metropolitan Life Insurance Company Conduct Rules NASD Rule 2510 - Discretionary Accounts
Feb 3, 2003 Interpretive Letter to Suart M. Strauss, Esq., Mayer, Brown, Rowe & Maw Conduct Rules NASD Rule 2830 - Investment Company Securities
Mar 17, 2003 Interpretive Letter to Alice Yau, J.P. Morgan Securities, Inc. Marketplace Rules NASD Rule 6200 Series - Trade Reporting and Compliance Engine (TRACE)
Apr 2, 2003 Interpretive Letter to Jess Haberman, royalblue financial corporation Marketplace Rules NASD Rules 6950-6957 (OATS)
Apr 3, 2003 Interpretive Letter to Adam Zentner, Credit Suisse First Boston (Europe) Limited Marketplace Rules NASD Rules 6950-6957 (OATS)
May 1, 2003 Interpretive Letter to Michael D. Wolk, Esq., Foley and Lardner (Use of Negative Response Letters) Conduct Rules NASD Rule 2110 - Standards of Commercial Honor and Principles of Trade
May 19, 2003 Interpretive Letter to James Hermann, William Blair & Company, LLC Marketplace Rules NASD Rule 6200 Series - Trade Reporting and Compliance Engine (TRACE)
May 29, 2003 Interpretive Letter to Robert C. Hacker, Esq., Kirkpatrick & Lockhart, LLP Conduct Rules NASD Rule 2210 - Communications with the Public
Jul 11, 2003 Interpretive Letter to Mustafa Fazel, National Financial Services, LLC Marketplace Rules NASD Rule 6200 Series - Trade Reporting and Compliance Engine (TRACE)
Sep 29, 2003 Interpretive Letter to Sarah A. Bessin, Esq., Shearman & Sterling LLP Conduct Rules NASD Rule 2830 - Investment Company Securities

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