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
May 21, 2010 Interpretive Letter to Claudia Crowley, NYSE Regulation, Inc. Marketplace Rules FINRA Rules 7410-7470 (OATS)
Sep 21, 1999 Interpretive Letter to Cliff Palefsky, Esq., National Employment Lawyers Association Procedural Rules NASD Rule 10301 - Required Submission
Aug 2, 2001 Interpretive Letter to Conrad C. Lysiak, Esq., Metropolitan Financial Center Procedural Rules NASD Rule 8300 Series - Sanctions
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
Nov 11, 1997 Interpretive Letter to Craig S. Tyle, Investment Company Institute Conduct Rules NASD Rule 2210 - Communications with the Public
Sep 28, 2007 Interpretive Letter to Dan Danborn, Society of Certified Senior Advisors Conduct Rules NASD Rule 2210 - Communications with the Public
Nov 24, 2003 Interpretive Letter to Dana Fleischman, Esq., Cleary, Gottlieb, Steen & Hamilton Conduct Rules NASD Rule 2740 - Selling Concessions, Discounts, and Other Allowances
Jun 1, 2004 Interpretive Letter to Dana G. Fleischman Conduct Rules NASD Rule 2790 - Restrictions on the Purchase and Sale of Initial Equity Public Offerings
Jun 18, 1998 Interpretive Letter to Daniel Schloendorn, Willkie Farr & Gallagher Conduct Rules NASD Rule 2710 - Corporate Financing Rule
Nov 13, 2002 Interpretive Letter to Danny Ho, Commerzbank Securities Marketplace Rules NASD Rule 6200 Series - Trade Reporting and Compliance Engine (TRACE)
Sep 25, 2001 Interpretive Letter to David A. Genelly, Esq., Vanasco Genelly & MIller Membership and Registration Rules NASD Rule 1030 Series - Registration of Representatives
Sep 25, 1997 Interpretive Letter to David M. Katz, Sidley & Austin Conduct Rules NASD Rule 2420 - Dealing with Non-Members
Aug 11, 2000 Interpretive Letter to David M. Rappaport, Esq., INVESTACORP Inc. Membership and Registration Rules NASD Rule 1030 Series - Registration of Representatives
Jul 30, 1998 Interpretive Letter to Dawn Bond, FSC Securities Corporation Conduct Rules NASD Rule 2210 - Communications with the Public
Nov 13, 2002 Interpretive Letter to Dennis C. Hensley, Sidley Austin Brown and Wood LLP Marketplace Rules NASD Rule 6200 Series - Trade Reporting and Compliance Engine (TRACE)
Jan 29, 2001 Interpretive Letter to Dennis Roth, Chesapeake Securities Research Corporation Membership and Registration Rules NASD Rule 1030 Series - Registration of Representatives
Sep 5, 2001 Interpretive Letter to Donald H. Meiers, Holland & Knight, LLP Conduct Rules NASD Rule 2320 - Best Execution and Interpositioning
Nov 4, 2002 Interpretive Letter to Donna B. Lawson, First Allied Securities, Inc. Conduct Rules NASD Rule 3040 - Private Securities Transactions of an Associated Person
Feb 3, 2003 Interpretive Letter to Doug Wright, The Investment Center, Inc. (Use of Negative Response Letters) Conduct Rules NASD Rule 2110 - Standards of Commercial Honor and Principles of Trade
May 12, 2015 Interpretive Letter to Edward P. Macdonald, Hartford Funds Distributors, LLC Conduct Rules FINRA Rule 2210 - Communications with the Public
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
Dec 7, 1998 Interpretive Letter to Elaine S. Moshe, Gordon Altman Butowsky Weitzen Conduct Rules NASD Rule 2830 - Investment Company Securities
May 9, 2017 Interpretive Letter to Elliott R. Curzon, Dechert LLP Conduct Rules FINRA Rule 5131 – New Issue Allocations and Distributions
Sep 27, 2001 Interpretive Letter to Elliott R. Curzon, Esq., Dechert Price & Rhoads Membership and Registration Rules NASD Rule 1030 Series - Registration of Representatives
Oct 12, 2000 Interpretive Letter to Eric A. Arnold, Esq., Sutherland Asbill & Brennan LLP Conduct Rules NASD Rule 2820 - Variable Contracts of an Insurance Company

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