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 Titlesort descending Type Related Rule / Topic
Jun 4, 2002 Interpretive Letter to Selwyn Notelovitz, Global Compliance Conduct Rules NASD Rule 3110 - Books and Records
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
Jul 19, 2000 Interpretive Letter to Stephen M. Vine, Esq., Akin, Gump, Strauss, Hauer & Feld, L.L.P. Membership and Registration Rules NASD Rule 1030 Series - Registration of Representatives
Jun 15, 2000 Interpretive Letter to Steven F. Gatti, Esq., Clifford, Chance, Rogers & Wells Conduct Rules NASD Rule 3110 - Books and Records
Sep 28, 2006 Interpretive Letter to Steven K. McGinnis, Loring Ward Securities, Inc. Conduct Rules NASD Rule 2830 - Investment Company Securities
Jan 23, 1997 Interpretive Letter to Stuart J. Kaswell, SIA Conduct Rules NASD Rule 2310 - Recommendations to Customers (Suitability)
Jan 16, 2001 Interpretive Letter to Stuart M. Strauss, Esq., Mayer, Brown & Platt Conduct Rules NASD Rule 2830 - Investment Company Securities
Feb 3, 2003 Interpretive Letter to Suart M. Strauss, Esq., Mayer, Brown, Rowe & Maw 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
Mar 16, 2005 Interpretive Letter to Tamara K. Salmon, Investment Company Institute Conduct Rules NASD Rule 2510 - Discretionary Accounts
Sep 6, 2007 Interpretive Letter to Tamara K. Salmon, Investment Company Institute Conduct Rules NASD 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
May 27, 1998 Interpretive Letter to Therese Haberle, Charles Schwab Membership and Registration Rules NASD Rule 1040 Series - Assistant Representative - Order Processing
Nov 29, 2004 Interpretive Letter to Therese Squillacote, ING Financial Advisers, LLC Conduct Rules NASD Rule 2210 - Communications with the Public
Aug 31, 2000 Interpretive Letter to Thomas E. Hellings, Securities America, Inc. Conduct Rules NASD Rule 2310 - Recommendations to Customers (Suitability)
Apr 19, 2001 Interpretive Letter to Thomas W. Hands, TradePortal Securities, Inc. Membership and Registration Rules NASD Rule 1030 Series - Registration of Representatives
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
Jan 29, 1999 Interpretive Letter to Trish Stone-Damen, Investors Retirement & Management Company, Inc. Conduct Rules NASD Rule 2420 - Dealing with Non-Members
Dec 7, 1998 Interpretive Letter to Victoria Bach-Fink, Wall Street Financial Group Conduct Rules NASD Rule 2420 - Dealing with Non-Members
Feb 5, 1999 Interpretive Letter to W. Thomas Conner, National Association for Variable Annuities Conduct Rules NASD Rule 2210 - Communications with the Public
Dec 1, 2014 Interpretive Letter to Wallace W. Kunzman, Jr., Kunzman & Bollinger, Inc. Membership and Registration Rules NASD Rule 1030 Series - Registration of Representatives
Jul 30, 1997 Interpretive Letter to Webster E. Janssen, Janssen Financial Services Conduct Rules NASD Rule 3030 - Outside Business Activities of an Association Person
Mar 26, 2010 Interpretive Letter to William D. Edick, Pickard and Djinis LLP Marketplace Rules FINRA Rules 7410-7470 (OATS)
Dec 17, 1999 Interpretive Letter to Yoon-Young Lee, Wilmer, Cutler & Pickering Conduct Rules NASD Rule 2210 - Communications with the Public
Dec 30, 2003 Interpretive Letter to Yukako Kawata, Davis Polk & Wardwell Conduct Rules NASD Rule 2210 - Communications with the Public

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