Notice to Members 99-55

Questions and Answers Relating to Non-Cash Compensation Rules

This Notice to Members addresses questions regarding the application of amendments recently adopted by the National Association of Securities Dealers, Inc. (NASD®) to NASD Rules 2820 (Variable Contracts Rule) and 2830 (Investment Company Rule). Generally, the new rules regulate compensation arrangements for the sale and distribution of variable products and investment company securities. To further facilitate member compliance with these rules, this Notice addresses questions that have been raised with respect to particular circumstances covered by the new rules.

Questions regarding this Notice may be directed to Joseph Savage, Counsel, Advertising/Investment Companies Regulation, NASD Regulation, Inc., (NASD Regulation®), at (202) 728-8233; Lawrence N. Kosciulek, Assistant Director, Advertising/Investment Companies Regulation, NASD Regulation, at (202) 728-8329; and Stephanie M. Dumont, Assistant General Counsel, Office of General Counsel, NASD Regulation, at (202) 728-8176.