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
Jul 5, 2001 Interpretive Letter to Jeffrey W. Kilduff, Esq., O'Melveny & Myers, LLP Conduct Rules NASD Rule 3110 - Books and Records
Dec 7, 1998 Interpretive Letter to Victoria Bach-Fink, Wall Street Financial Group Conduct Rules NASD Rule 2420 - Dealing with Non-Members
May 28, 1996 Interpretive Letter to Name Not Public Conduct Rules NASD Rule 3070 - Reporting Requirements
Feb 20, 2015 Interpretive Letter to Gregory J. Nowak, Pepper Hamilton LLP Conduct Rules FINRA Rule 5130 - Restrictions on the Purchase and Sale of Initial Equity Public Offerings
Aug 31, 2000 Interpretive Letter to Thomas E. Hellings, Securities America, Inc. Conduct Rules NASD Rule 2310 - Recommendations to Customers (Suitability)
Aug 9, 1996 Interpretive Letter to Name Not Public Conduct Rules NASD Rule 3010 - Supervision
Dec 28, 2007 Interpretive Letter to Richard Schultz, Triad Securities Corp. Conduct Rules NASD Rule 2420 - Dealing with Non-Members
Feb 3, 2003 Interpretive Letter to Suart M. Strauss, Esq., Mayer, Brown, Rowe & Maw Conduct Rules NASD Rule 2830 - Investment Company Securities
Nov 29, 2004 Interpretive Letter to Therese Squillacote, ING Financial Advisers, LLC Conduct Rules NASD Rule 2210 - Communications with the Public
Jun 18, 1998 Interpretive Letter to Daniel Schloendorn, Willkie Farr & Gallagher Conduct Rules NASD Rule 2710 - Corporate Financing Rule
May 25, 2001 Interpretive Letter to Name Not Public Conduct Rules NASD Rule 3370 - Prompt Receipt and Delivery of Securities
Nov 27, 2000 Interpretive Letter to Angela Coronado, Brecek & Young Advisors, Inc. Conduct Rules NASD Rule 3110 - Books and Records
Sep 16, 1998 Interpretive Letter to Brian C. Underwood, A.G. Edwards & Sons, Inc. Conduct Rules NASD Rule 2420 - Dealing with Non-Members
May 28, 1996 Interpretive Letter to Name Not Public Conduct Rules NASD Rule 3070 - Reporting Requirements
May 12, 2015 Interpretive Letter to Edward P. Macdonald, Hartford Funds Distributors, LLC Conduct Rules FINRA Rule 2210 - Communications with the Public
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
May 15, 2008 Letter from FINRA Office of General Counsel, May 15, 2008 Conduct Rules NASD Rule 2510 - Discretionary Accounts
Oct 29, 2002 Interpretive Letter to Kathleen H. Moriarty, Esq., Carter, Ledyard & Milburn Conduct Rules NASD Rule 2830 - Investment Company Securities
Nov 24, 2003 Interpretive Letter to Dana Fleischman, Esq., Cleary, Gottlieb, Steen & Hamilton Conduct Rules NASD Rule 2740 - Selling Concessions, Discounts, and Other Allowances
Dec 9, 1997 Interpretive Letter to Lee A. Pickard, Pickard and Djinis Conduct Rules NASD Rule 2740 - Selling Concessions, Discounts, and Other Allowances
Apr 27, 2001 Interpretive Letter to Name Not Public Conduct Rules NASD Rule 3370 - Prompt Receipt and Delivery of Securities
Aug 4, 2000 Interpretive Letter to Alan Feldstein, Esq., Development Corporation for Israel Conduct Rules NASD Rule 3110 - Books and Records
Sep 25, 1997 Interpretive Letter to David M. Katz, Sidley & Austin Conduct Rules NASD Rule 2420 - Dealing with Non-Members
Jan 23, 1997 Interpretive Letter to Stuart J. Kaswell, SIA Conduct Rules NASD Rule 2310 - Recommendations to Customers (Suitability)

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