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Interpretive Letter

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 Related Rule Core Topic
Feb 17, 2004 Interpretive Letter to Tom Fleming, Dealogic NASD Rule 2790 - Restrictions on the Purchase and Sale of Initial Equity Public Offerings
Feb 04, 2004 Interpretive Letter to Martin H. Kaplan, Esq., Gusrae, Kaplan & Bruno, PLLC NASD Rule 2330 - Customers' Securities or Funds
Dec 30, 2003 Interpretive Letter to Yukako Kawata, Davis Polk & Wardwell NASD Rule 2210 - Communications with the Public Related Performance, Advertising Regulation
Nov 24, 2003 Interpretive Letter to Dana Fleischman, Esq., Cleary, Gottlieb, Steen & Hamilton NASD Rule 2740 - Selling Concessions, Discounts, and Other Allowances
Nov 07, 2003 Interpretive Letter to Harold L. Gladney NASD Rule 2370 - Borrowing From or Lending to Customers
Oct 02, 2003 Interpretive Letter to Michael D. Udoff, Securities Industry Association NASD Rule 2210 - Communications with the Public Hedge Funds, Related Performance, Advertising Regulation
Sep 29, 2003 Interpretive Letter to Sarah A. Bessin, Esq., Shearman & Sterling LLP NASD Rule 2830 - Investment Company Securities
Jul 11, 2003 Interpretive Letter to Mustafa Fazel, National Financial Services, LLC NASD Rule 6200 Series - Trade Reporting and Compliance Engine (TRACE)
May 29, 2003 Interpretive Letter to Robert C. Hacker, Esq., Kirkpatrick & Lockhart, LLP NASD Rule 2210 - Communications with the Public Advertising Regulation, Proprietary Trading
May 19, 2003 Interpretive Letter to James Hermann, William Blair & Company, LLC NASD Rule 6200 Series - Trade Reporting and Compliance Engine (TRACE)
May 01, 2003 Interpretive Letter to Michael D. Wolk, Esq., Foley and Lardner (Use of Negative Response Letters) NASD Rule 2110 - Standards of Commercial Honor and Principles of Trade Negative Response Letters, Advertising Regulation, Customer Account Transfers, Mergers Acquisitions and Business Transfers
Apr 03, 2003 Interpretive Letter to Adam Zentner, Credit Suisse First Boston (Europe) Limited NASD Rules 6950-6957 (OATS)
Apr 02, 2003 Interpretive Letter to Jess Haberman, royalblue financial corporation NASD Rules 6950-6957 (OATS)
Mar 17, 2003 Interpretive Letter to Alice Yau, J.P. Morgan Securities, Inc. NASD Rule 6200 Series - Trade Reporting and Compliance Engine (TRACE)
Feb 03, 2003 Interpretive Letter to Suart M. Strauss, Esq., Mayer, Brown, Rowe & Maw NASD Rule 2830 - Investment Company Securities
Feb 03, 2003 Interpretive Letter to Marc. A. Cohn, Metropolitan Life Insurance Company NASD Rule 2510 - Discretionary Accounts Mergers Acquisitions and Business Transfers
Feb 03, 2003 Interpretive Letter to Doug Wright, The Investment Center, Inc. (Use of Negative Response Letters) NASD Rule 2110 - Standards of Commercial Honor and Principles of Trade Negative Response Letters, Advertising Regulation, Mergers Acquisitions and Business Transfers
Feb 03, 2003 Interpretive Letter to Pamela M. Krill, Esquire, Godfrey & Kahn, S.C. NASD Rule 2830 - Investment Company Securities
Feb 03, 2003 Interpretive Letter to Marilyn A. Sponzo, Jordan Burt NASD Rule 2820 - Variable Contracts of an Insurance Company
Feb 03, 2003 Interpretive Letter to Marion A. Kashan, London Pacific Securities, Inc. (Use of Negative Response Letters) NASD Rule 2110 - Standards of Commercial Honor and Principles of Trade Negative Response Letters, Advertising Regulation, Customer Account Transfers, Mergers Acquisitions and Business Transfers
Feb 03, 2003 Interpretive Letter to Marilyn J. Sponzo, Jorden Burt Gifts, Gratuities and Non-Cash Compensation, Variable Annuities
Feb 03, 2003 Interpretive Letter to Pamela M. Krill, Esquire, Godfrey & Kahn, S.C. NASD Rule 2820 - Variable Contracts of an Insurance Company
Dec 12, 2002 Interpretive Letter to R. Cromwell Coulson, Pink Sheets LLC NASD Rule 2110 - Standards of Commercial Honor and Principles of Trade
Nov 13, 2002 Interpretive Letter to Danny Ho, Commerzbank Securities NASD Rule 6200 Series - Trade Reporting and Compliance Engine (TRACE)
Nov 13, 2002 Interpretive Letter to Dennis C. Hensley, Sidley Austin Brown and Wood LLP NASD Rule 6200 Series - Trade Reporting and Compliance Engine (TRACE)