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 23, 1996 Interpretive Letter to Name Not Public Conduct Rules NASD Rule 3040 - Private Securities Transactions of an Associated Person
Apr 28, 2014 Interpretive Letter to Russell D. Sacks, Shearman & Sterling LLP Conduct Rules NASD Rule 2711 - Research Analysts and Research Reports
Nov 26, 2001 Interpretive Letter to Name Not Public Conduct Rules NASD Rule 3010 - Supervision
May 1, 2003 Interpretive Letter to Michael D. Wolk, Esq., Foley and Lardner (Use of Negative Response Letters) Conduct Rules NASD Rule 2110 - Standards of Commercial Honor and Principles of Trade
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
Mar 7, 2001 Interpretive Letter to Name Not Public Conduct Rules NASD Rule 2820 - Variable Contracts of an Insurance Company
May 15, 2001 Interpretive Letter to Charles Freund, Brown Brothers Harriman Conduct Rules NASD Rule 3220 - Adjustment of Open Orders
Feb 3, 2005 Interpretive Letter to Michael R. Trocchio, Esq., Bingham McCutchen LLP Conduct Rules NASD Rule 2110 - Standards of Commercial Honor and Principles of Trade
Jan 26, 2005 Interpretive Letter to George T. Simon, Foley & Lardner, LLP Conduct Rules NASD Rule 2510 - Discretionary Accounts
Dec 23, 1996 Interpretive Letter to Name Not Public Conduct Rules NASD IM-2420-2 - Continuing Commissions Policy
Feb 5, 1999 Interpretive Letter to W. Thomas Conner, National Association for Variable Annuities Conduct Rules NASD Rule 2210 - Communications with the Public
Oct 31, 1995 Interpretive Letter to Name Not Public Conduct Rules NASD Rule 3110 - Books and Records
Mar 8, 2001 Interpretive Letter to Jay Adams Knight, Esq., Musick, Peeler & Garrett LLP Conduct Rules NASD Rule 2420 - Dealing with Non-Members
Sep 27, 1994 Interpretive Letter to Name Not Public Conduct Rules NASD Rule 3040 - Private Securities Transactions of an Associated Person
Jun 4, 2001 Interpretive Letter to Lena M. Stinson, Stanford Group Company Conduct Rules NASD Rule 3010 - Supervision
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
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
Aug 29, 1997 Interpretive Letter to Lloyd H. Feller, Morgan, Lewis & Bockius Conduct Rules NASD IM-3310 - Manipulative and Deceptive Quotations
Nov 29, 2004 Interpretive Letter to Therese Squillacote, ING Financial Advisers, LLC Conduct Rules NASD Rule 2210 - Communications with the Public
Nov 20, 1996 Interpretive Letter to Name Not Public Conduct Rules NASD IM-2420-2 - Continuing Commissions Policy
Jul 30, 1998 Interpretive Letter to Dawn Bond, FSC Securities Corporation Conduct Rules NASD Rule 2210 - Communications with the Public
Jul 5, 2001 Interpretive Letter to Jeffrey W. Kilduff, Esq., O'Melveny & Myers, LLP Conduct Rules NASD Rule 3110 - Books and Records
Sep 27, 2000 Interpretive Letter to Kathleen A. Wieland, William Blair & Company Conduct Rules NASD Rule 2420 - Dealing with Non-Members
Aug 5, 1994 Interpretive Letter to Name Not Public Conduct Rules NASD Rule 3040 - Private Securities Transactions of an Associated Person
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

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