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
Mar 1, 2002 Interpretive Letter to Frank Almeida, Quality of Life Settlements Conduct Rules NASD Rule 3030 - Outside Business Activities of an Association Person
Nov 27, 2012 Interpretive Letter to Name Not Public Conduct Rules NASD IM-2420-2 - Continuing Commissions Policy
Jun 18, 2001 Interpretive Letter to Philip J. Fina, Esq., Kirkpatrick & Lockhart LLP Conduct Rules NASD Rule 2830 - Investment Company Securities
Jul 26, 1995 Interpretive Letter to Richard Lewandowski, The Options Exchange Conduct Rules NASD Rule 3370 - Prompt Receipt and Delivery of Securities
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
Dec 9, 1997 Interpretive Letter to Lee A. Pickard, Pickard and Djinis 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
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
Sep 25, 1997 Interpretive Letter to David M. Katz, Sidley & Austin Conduct Rules NASD Rule 2420 - Dealing with Non-Members
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 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
Jan 16, 2001 Interpretive Letter to Stuart M. Strauss, Esq., Mayer, Brown & Platt Conduct Rules NASD Rule 2830 - Investment Company Securities
Feb 8, 1999 Interpretive Letter to Roger D. Blanc, Esq., Willkie Farr & Gallagher Conduct Rules NASD Rule 3350 - Short Sale Rule
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
Nov 15, 1996 Interpretive Letter to Name Not Public Conduct Rules NASD Rule 2740 - Selling Concessions, Discounts, and Other Allowances
Oct 2, 2003 Interpretive Letter to Michael D. Udoff, Securities Industry Association Conduct Rules NASD Rule 2210 - Communications with the Public
Sep 30, 2002 Interpretive Letter to Susan S. Krawczyk, Esq., Sutherland Asbill & Brennan LLP Conduct Rules NASD Rule 2210 - Communications with the Public
Aug 20, 1997 Interpretive Letter to Peter D. Koffler, Twenty-First Securities Corporation Conduct Rules NASD Rule 2420 - Dealing with Non-Members
Jan 31, 2019 Interpretive letter to Meredith F. Henning, Foreside Conduct Rules FINRA Rule 2210 - Communications with the Public
Jan 23, 1997 Interpretive Letter to Paul Saltzman, PSA Conduct Rules NASD Rule 2310 - Recommendations to Customers (Suitability)
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
Oct 26, 1997 Interpretive Letter to Paul D. Coury, The Coury Financial Group Conduct Rules NASD Rule 3030 - Outside Business Activities of an Association Person
Mar 18, 2001 Interpretive Letter to Klia Ververidis, Esq., AssetStream Corporation Conduct Rules NASD Rule 2110 - Standards of Commercial Honor and Principles of Trade
Feb 5, 2013 Interpretive Letter to S. Kendrick Dunn, Pacific Select Distributors, Inc. Conduct Rules NASD Rule 3010 - Supervision

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