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
Oct 2, 2003 Interpretive Letter to Michael D. Udoff, Securities Industry Association Conduct Rules NASD Rule 2210 - Communications with the Public
Nov 7, 2003 Interpretive Letter to Harold L. Gladney Conduct Rules NASD Rule 2370 - Borrowing From or Lending to Customers
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 30, 2003 Interpretive Letter to Yukako Kawata, Davis Polk & Wardwell Conduct Rules NASD Rule 2210 - Communications with the Public
Feb 4, 2004 Interpretive Letter to Martin H. Kaplan, Esq., Gusrae, Kaplan & Bruno, PLLC Conduct Rules NASD Rule 2330 - Customers' Securities or Funds
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 5, 2004 Interpretive Letter to Mr. Alan E. Sorcher, Securities Industry Association & Ms. Sarah A. Miller, ABA Securities Association Membership and Registration Rules NASD Rule 1070 - Qualification Examinations and Waiver of Requirements
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
Aug 20, 2004 Interpretive Letter to Mark W. Riepe, Charles Schwab & Co., Inc. Conduct Rules NASD Rule 2711 - Research Analysts and Research Reports
Sep 14, 2004 Interpretive Letter to Budge Collins, Collins/Bay Island Securities Conduct Rules NASD Rule 2210 - Communications with the Public
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
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
Nov 10, 2004 Interpretive Letter to Michael R. Trocchio, Esq., Bingham McCutchen LLP Conduct Rules NASD Rule 2110 - Standards of Commercial Honor and Principles of Trade
Nov 29, 2004 Interpretive Letter to Therese Squillacote, ING Financial Advisers, LLC Conduct Rules NASD Rule 2210 - Communications with the Public
Jan 26, 2005 Interpretive Letter to George T. Simon, Foley & Lardner, LLP Conduct Rules NASD Rule 2510 - Discretionary Accounts
Feb 3, 2005 Interpretive Letter to Michael R. Trocchio, Esq., Bingham McCutchen LLP Conduct Rules NASD Rule 2110 - Standards of Commercial Honor and Principles of Trade
Mar 16, 2005 Interpretive Letter to Tamara K. Salmon, Investment Company Institute Conduct Rules NASD Rule 2510 - Discretionary Accounts
Dec 12, 2005 Interpretive Letter to Mr. Alan E. Sorcher, Securities Industry Association & Ms. Sarah A. Miller, ABA Securities Association Membership and Registration Rules NASD Rule 1070 - Qualification Examinations and Waiver of Requirements
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
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
Aug 14, 2006 NASD Office of General Counsel, Regulatory Policy and Oversight Conduct Rules NASD Rule 2830 - Investment Company Securities
Aug 15, 2006 NASD Office of General Counsel, Regulatory Policy and Oversight Conduct Rules NASD Rule 2110 - Standards of Commercial Honor and Principles of Trade
Sep 28, 2006 Interpretive Letter to Steven K. McGinnis, Loring Ward Securities, Inc. 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

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