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 28, 1996 Interpretive Letter to Name Not Public Conduct Rules NASD Rule 3070 - Reporting Requirements
Oct 6, 2006 Interpretive Letter to Alan M. Wolper, Esq., Sutherland Asbill & Brennan LLP Conduct Rules NASD Rule 2460 - Payments for Market Making
Mar 4, 1997 Interpretive Letter to Name Not Public Conduct Rules NASD Rule 2310 - Recommendations to Customers (Suitability)
Mar 1, 2002 Interpretive Letter to Frank Almeida, Quality of Life Settlements Conduct Rules NASD Rule 3030 - Outside Business Activities of an Association Person
Apr 27, 2001 Interpretive Letter to Name Not Public Conduct Rules NASD Rule 3370 - Prompt Receipt and Delivery of Securities
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
Jun 18, 2001 Interpretive Letter to Philip J. Fina, Esq., Kirkpatrick & Lockhart LLP Conduct Rules NASD Rule 2830 - Investment Company Securities
Dec 9, 1997 Interpretive Letter to Lee A. Pickard, Pickard and Djinis Conduct Rules NASD Rule 2740 - Selling Concessions, Discounts, and Other Allowances
Apr 22, 2013 Interpretive Letter to Bradley J. Swenson, ALPS Distributors, Inc. Conduct Rules FINRA Rule 2210 - Communications with the Public
Sep 25, 1997 Interpretive Letter to David M. Katz, Sidley & Austin Conduct Rules NASD Rule 2420 - Dealing with Non-Members
Nov 30, 2006 Interpretive Letter to Evan Charkes, Citigroup Global Markets, Inc. Conduct Rules NASD Rule 3010 - Supervision
Jan 23, 1997 Interpretive Letter to Stuart J. Kaswell, SIA Conduct Rules NASD Rule 2310 - Recommendations to Customers (Suitability)
Dec 6, 2001 Interpretive Letter to Sheryl Anne Zuckerman, Esq., Singer Frumento LLP Conduct Rules NASD Rule 3030 - Outside Business Activities of an Association Person
Dec 23, 1999 Interpretive Letter to R. Bruce Hughes, Access Mortgage Services, Inc. Conduct Rules NASD Rule 3030 - Outside Business Activities of an Association Person
Jun 20, 2000 Interpretive Letter to Robinson Markel, Esq., Rosenman & Colin, LLP Conduct Rules NASD Rule 3370 - Prompt Receipt and Delivery of Securities
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
Jan 16, 2001 Interpretive Letter to Stuart M. Strauss, Esq., Mayer, Brown & Platt Conduct Rules NASD Rule 2830 - Investment Company Securities
Apr 16, 1997 Interpretive Letter to Name Not Public Conduct Rules NASD IM-2110-2 - Trading Ahead of Customer Limit Order
Nov 15, 1996 Interpretive Letter to Name Not Public Conduct Rules NASD Rule 2740 - Selling Concessions, Discounts, and Other Allowances
Aug 26, 2013 Interpretive Letter to Brian Sweeney, Trustmont Financial Group, Inc. Conduct Rules FINRA Rule 2111 - Suitability
Aug 20, 1997 Interpretive Letter to Peter D. Koffler, Twenty-First Securities Corporation Conduct Rules NASD Rule 2420 - Dealing with Non-Members
Sep 6, 2007 Interpretive Letter to Tamara K. Salmon, Investment Company Institute Conduct Rules NASD Rule 2210 - Communications with the Public
Jan 23, 1997 Interpretive Letter to Paul Saltzman, PSA Conduct Rules NASD Rule 2310 - Recommendations to Customers (Suitability)
Sep 28, 2007 Interpretive Letter to Dan Danborn, Society of Certified Senior Advisors Conduct Rules NASD Rule 2210 - Communications with the Public
Aug 19, 2002 Interpretive Letter to Howard L. Kramer, Schiff Hardin & Waite Conduct Rules NASD Rule 2320 - Best Execution and Interpositioning

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