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Interpretive Letter to Therese Haberle, Charles Schwab

May 27, 1998


By Facsimile and First Class Mail

Ms. Therese Haberle
Chief Compliance Officer & Senior Vice President
Charles Schwab
101 Montgomery Street
San Francisco, California 94104

Dear Ms. Haberle:

Mary Alice Brophy asked me to respond to your letters of March 9 and May 11 proposing that unregistered Customer Service Representatives be permitted to transcribe customer orders from taped lines during certain periods of peak telephone call volume. Your proposal was reviewed by the Membership Committee on May 14 and by the Office of General Counsel. Both the Membership Committee and the Office of General Counsel agree that appropriate way for your firm to prepare for above-average call volume is to register additional personnel as Assistant Representatives for Order Processing (Series 11). NASD Rule 1041 describes activities in which such representatives may engage, which are consistent with the activities proposed in your letters.

While the Committee and the Office of General Counsel do not believe it is appropriate to grant broad-based waivers of registration requirements based on market activity or volume, the NASD will continue to be responsive to specific requests to accommodate client needs during times of extraordinary market conditions.

If you have any further questions, please call me at (202) 728-8252.

Very truly yours,

Mary M. Dunbar
Assistant General Counsel

cc: Mary Alice Brophy