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
Jul 9, 2008 FINRA Office of General Counsel (Auction Rate Securities) Conduct Rules NASD Rule 2110 - Standards of Commercial Honor and Principles of Trade
Apr 3, 2003 Interpretive Letter to Adam Zentner, Credit Suisse First Boston (Europe) Limited Marketplace Rules NASD Rules 6950-6957 (OATS)
Aug 4, 2000 Interpretive Letter to Alan Feldstein, Esq., Development Corporation for Israel Conduct Rules NASD Rule 3110 - Books and Records
Oct 6, 2006 Interpretive Letter to Alan M. Wolper, Esq., Sutherland Asbill & Brennan LLP Conduct Rules NASD Rule 2460 - Payments for Market Making
Mar 17, 2003 Interpretive Letter to Alice Yau, J.P. Morgan Securities, Inc. Marketplace Rules NASD Rule 6200 Series - Trade Reporting and Compliance Engine (TRACE)
Oct 2, 2000 Interpretive Letter to Allan H. Pessin, Securities Compliance Consultants Inc. Membership and Registration Rules NASD Rule 1020 Series - Registration of Principals
Dec 17, 2007 Interpretive Letter to Amal Aly, SIFMA (Reasonable and Customary Bereavement Gifts) Conduct Rules NASD Rule 3060 - Influencing or Rewarding Employees of Others
Feb 8, 2013 Interpretive Letter to Amy Natterson Kroll, Bingham McCutchen LLP Conduct Rules NASD Rule 2711 - Research Analysts and Research Reports
Nov 11, 1999 Interpretive Letter to Andrew Gotfried, Raymond James Financial Services Membership and Registration Rules NASD Rule 1030 Series - Registration of Representatives
Nov 27, 2000 Interpretive Letter to Angela Coronado, Brecek & Young Advisors, Inc. Conduct Rules NASD Rule 3110 - Books and Records
Dec 22, 2000 Interpretive Letter to Barbara A. Mallon, Esq., Mallon & Johnson, P.C. Conduct Rules NASD Rule 2110 - Standards of Commercial Honor and Principles of Trade
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
Jun 19, 1997 Interpretive Letter to Bill T. Singer, Singer Zamansky LLP Membership and Registration Rules NASD Rule 1030 Series - Registration of Representatives
Aug 7, 2001 Interpretive Letter to Bob E. Lehman, Esq., Lehman & Eilen LLP Conduct Rules NASD Rule 3230 - Clearing Agreements
Apr 22, 2013 Interpretive Letter to Bradley J. Swenson, ALPS Distributors, Inc. Conduct Rules FINRA Rule 2210 - Communications with the Public
Dec 11, 2000 Interpretive Letter to Brian C. Sullivan, LaBranche & Co. Membership and Registration Rules NASD Rule 1060 - Persons Exempt from Registration
Sep 16, 1998 Interpretive Letter to Brian C. Underwood, A.G. Edwards & Sons, Inc. Conduct Rules NASD Rule 2420 - Dealing with Non-Members
Aug 26, 2013 Interpretive Letter to Brian Sweeney, Trustmont Financial Group, Inc. Conduct Rules FINRA Rule 2111 - Suitability
Sep 14, 2004 Interpretive Letter to Budge Collins, Collins/Bay Island Securities Conduct Rules NASD Rule 2210 - Communications with the Public
May 15, 2001 Interpretive Letter to Charles Freund, Brown Brothers Harriman Conduct Rules NASD Rule 3220 - Adjustment of Open Orders
Jul 30, 1998 Interpretive Letter to Charles R. Hood, Instinet Corporation Marketplace Rules NASD Rules 6950-6957 (OATS)
Mar 14, 2001 Interpretive Letter to Charles Wiegert, NFP Securities Conduct Rules NASD Rule 3060 - Influencing or Rewarding Employees of Others
Feb 26, 2002 Interpretive Letter to Christian M. Camerino, ABN AMRO Securities, LLC Marketplace Rules NASD Rules 6950-6957 (OATS)
Jun 8, 1998 Interpretive Letter to Christine A. Edwards, Morgan Stanley Dean Witter & Co. Conduct Rules NASD Rule 2210 - Communications with the Public
Jun 12, 2017 Interpretive Letter to Clair Pagnano, K&L Gates LLP Conduct Rules FINRA Rule 2210 - Communications with the Public

Pages