Notice to Members 99-37

NASD Reminds Members of Their Obligations Regarding Electronic Distribution of Nasdaq and OTC Market Data

The National Association of Securities Dealers, Inc. (NASD®) requires member firms that distribute Nasdaq®, OTC Bulletin Board®, and/or other OTC market data through on-line trading systems or other electronic distribution media, including the Internet, to follow all Nasdaq market data distribution policies. Electronic media include—but are not limited to—member firm on-line trading systems that provide market data in support of trading activities. Market data distribution requirements include fulfillment of contractual obligations, accurate and non-misleading display of market data, reporting of fee-liable usage, and administration of subscriber agreements with end users of Nasdaq market data. This Notice provides explanations of these policies and requirements as they apply to on-line trading systems, electronic distribution media, and Internet distribution.

Questions concerning this Notice may be directed to Nasdaq Trading and Market Services at (202) 728-8480. Additional information and documentation is also available at the Nasdaq TraderSM Web Site (