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 25, 2001 Interpretive Letter to Name Not Public Conduct Rules NASD IM-2420-2 - Continuing Commissions Policy
Jul 3, 1997 Interpretive Letter to Name Not Public Conduct Rules NASD IM-2110-2 - Trading Ahead of Customer Limit Order
Mar 15, 1999 Interpretive Letter to Martin Miller, Esq., Willkie Farr & Gallagher Conduct Rules NASD Rule 2330 - Customers' Securities or Funds
Aug 4, 1997 Interpretive Letter to Name Not Public Conduct Rules NASD Rule 3040 - Private Securities Transactions of an Associated Person
Nov 27, 2000 Interpretive Letter to Angela Coronado, Brecek & Young Advisors, Inc. Conduct Rules NASD Rule 3110 - Books and Records
Feb 17, 1999 Interpretive Letter to Name Not Public Conduct Rules NASD Rule 2860 - Options
May 12, 2015 Interpretive Letter to Edward P. Macdonald, Hartford Funds Distributors, LLC Conduct Rules FINRA Rule 2210 - Communications with the Public
Oct 29, 1999 Interpretive Letter to Robert E. Lee, Counsel, P&A Administrative Services, Inc. Conduct Rules NASD Rule 2820 - Variable Contracts of an Insurance Company
Sep 18, 1996 Interpretive Letter to Name Not Public Conduct Rules NASD Rule 3370 - Prompt Receipt and Delivery of Securities
Jan 21, 2000 Interpretive Letter to Peter D. Koffler, Esq., Twenty-First Securities Corporation Conduct Rules NASD IM-2420-2 - Continuing Commissions Policy
Mar 16, 2005 Interpretive Letter to Tamara K. Salmon, Investment Company Institute Conduct Rules NASD Rule 2510 - Discretionary Accounts
Aug 29, 1997 Interpretive Letter to Lloyd H. Feller, Morgan, Lewis & Bockius Conduct Rules NASD Rule 2120 - Use of Manipulative, Deceptive, or Other Fraudulent Devices
Nov 7, 2003 Interpretive Letter to Harold L. Gladney Conduct Rules NASD Rule 2370 - Borrowing From or Lending to Customers
Dec 16, 1996 Interpretive Letter to Name Not Public Conduct Rules NASD Rule 3040 - Private Securities Transactions of an Associated Person
Aug 4, 2000 Interpretive Letter to Alan Feldstein, Esq., Development Corporation for Israel Conduct Rules NASD Rule 3110 - Books and Records
Feb 24, 1993 Interpretive Letter to Name Not Public Conduct Rules NASD Rule 2860 - Options
Mar 22, 2016 Interpretive Letter to Craig P. Hoffman, Esq., APM, American Retirement Association, Chris DeGrassi, National Tax-deferred Savings Association, and Richard K. Matta, Esq., Groom Law Group Conduct Rules FINRA Rule 2210 - Communications with the Public
Mar 7, 2001 Interpretive Letter to Name Not Public Conduct Rules NASD Rule 2820 - Variable Contracts of an Insurance Company
Jul 9, 2008 FINRA Office of General Counsel (Auction Rate Securities) Conduct Rules NASD Rule 2110 - Standards of Commercial Honor and Principles of Trade
Jul 26, 1995 Interpretive Letter to Richard Lewandowski, The Options Exchange Conduct Rules NASD Rule 3370 - Prompt Receipt and Delivery of Securities
Dec 9, 1998 Interpretive Letter to Leslie D. Smith, Berthel Fisher & Company Conduct Rules NASD IM-2420-2 - Continuing Commissions Policy
Dec 30, 2003 Interpretive Letter to Yukako Kawata, Davis Polk & Wardwell Conduct Rules NASD Rule 2210 - Communications with the Public
Jun 27, 2001 Interpretive Letter to Jonathan K. Lagemann, Esq., Law Offices of Jonathan Kord Lagemann Conduct Rules NASD Rule 2420 - Dealing with Non-Members
Jul 23, 1996 Interpretive Letter to Name Not Public Conduct Rules NASD Rule 3040 - Private Securities Transactions of an Associated Person
Jun 15, 2000 Interpretive Letter to Steven F. Gatti, Esq., Clifford, Chance, Rogers & Wells Conduct Rules NASD Rule 3110 - Books and Records

Pages