Guidance

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Interpretive Letter
Interpretive Letter to Howard L. Kramer, Schiff Hardin & Waite

Priced quotations by an ECN or ATS displayed on the OTC Bulletin Board are considered priced quotations for purposes of compliance with Rule 2320(g)(1).

August 19, 2002
Exemptive Letter
Name Not Public
Exemptive relieve is granted based on the following considerations: (1) Firm A took prompt action once it became aware of the Contribution by instituting a self-ban on any Issuer new business solicitation; (2) Firm A sent an electronic reminder to all Firm A and Firm A affiliate employees about Firm A's requirements for pre-clearance of all political contributions; (3) at the time of the Contribution, Name had no personal involvement in soliciting new, or participating in existing, municipal securities business; (4) Firm A has now offered to put in place processes to help ensure the segregation of Issuer information flow, minimizing the potential for quid pro quo resulting from the contribution; and (5) although a less weighty factor, the contribution was returned.
August 15, 2002
Exemptive Letter
Name Not Public
Exemptive relief is granted based on the following factors: (1) the Contribution was made by Company prior to signing an acquisition agreement with the Firm Parent;6 (2) at the time of the contribution Company had no involvement in soliciting new, or participating in existing, municipal securities business; (3) Company has been acquired by the Firm Parent and merged into Firm Y, an existing subsidiary of the Firm Parent that reports to and is controlled by the equities business unit of the Firm; (4) Firm Y securities information flow is controlled by NYSE approved information barriers designed to prevent the use of confidential information and conflicts of interest, minimizing the potential for quid pro quo resulting from the Contribution; (5) the Firm has put in place additional processes to ensure the segregation of the acquired Company business operations and its principals from State Business; and (6) although a less weighty factor, the Contribution was returned.
June 27, 2002
Exemptive Letter
Name Not Public
Exemptive relief is granted based on the following considerations: (1) the contributions were made prior to Individual's employment by the Firm; and (2) at the time of the contributions, Individual had no personal involvement in soliciting new, or participating in existing municipal securities business.
June 11, 2002
Interpretive Letter
Interpretive Letter to Selwyn Notelovitz, Global Compliance

Permissibility of electronic approval of accounts under NASD Rule 3110(c)(1)(C). (Note: Underlining indicates redactions from original letter).

June 04, 2002
Regulatory and Compliance Alerts (RCA)
Regulatory & Compliance Alert - Summer 2002
June 01, 2002
Exemptive Letter
Name Not Public
Exemptive relief is granted based on the following factors: (1.) prior to Name's contribution, Firm X maintained a thorough and comprehensive set of procedures reasonably designed to ensure compliance with the Rule; (2.) the Firm had no knowledge of Name's contribution; (3.) once Firm X learned of Name's contribution, it took all available steps to return of the contribution; (4.) Firm X took appropriate remedial or preventive measures.
May 15, 2002
Exemptive Letter
Name Not Public
Exemptive relief is granted based on the following considerations: (1) the Contribution was made nine months after Name last held a position which would have resulted in his designation as an MFP; (2) since becoming a Title of Company C, Name continues to be designated an MFP only because of the Rule’s two-year “look back” provision; (3) at the time Name was a member of the Firm X Board, Name had no personal day-to-day involvement in Firm X's municipal securities activities, and, since resigning from the Firm X Board, Name has had no involvement in the Firm’s municipal securities business; and (4) , the Contribution was returned and was small.
May 01, 2002
Guidance
Improving Examination Results - April 2002

October 2002

April 01, 2002
Regulatory and Compliance Alerts (RCA)
Regulatory & Compliance Alert - Spring 2002
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March 01, 2002
Interpretive Letter
Interpretive Letter to Frank Almeida, Quality of Life Settlements

Application of Rules 3030 and 3040 to associated persons who receive commissions for brokering viatical settlement contracts.

March 01, 2002
Interpretive Letter
Interpretive Letter to Christian M. Camerino, ABN AMRO Securities, LLC

Application of the OATS rules to orders that are cancelled or replaced due to a merger of the member holding the orders.

February 26, 2002
Interpretive Letter
Interpretive Letter to Ted. A. Troutman, Esquire, Muir & Troutman

Member firms may pay retired registered representatives continuing commissions based on contributions to accounts established by the former representatives prior to retirement, provided the conditions of NASD IM-2420-2 are satisfied, and further, that such payments are made in compliance with SEC "no-action" letters addressing the permissibility of those payments under Section 15(a) of the Securities Exchange Act of 1934. Firms cannot pay retired registered representatives commissions based on activity in accounts established after the representatives' retirement.

February 04, 2002
Exemptive Letter
Name Not Public
Exemptive relief is denied based on the following considerations: (1) this marks the second time in three years that Name made a political contribution without following the Firm’s established pre-clearance processes resulting in a prohibition of municipal securities business under the Rule;5 and (2) Name has an extremely high profile within the Firm and the state’s political and business community. -
January 29, 2002
Interpretive Letter
Interpretive Letter to Forrest R. Foss, T. Rowe Price Associates, Inc.
Rule 2210 does not require member to approve, file or maintain as advertising records certain statistical information that is regularly updated on firm's web site.
January 28, 2002
Interpretive Letter
Interpretive Letter to Name Not Public

Applicability of the reporting requirement under Rule 3070(a)(8) to a non-securities related automobile insurance settlement exceeding $15,000.

January 02, 2002
Interpretive Letter
Interpretive Letter to Sheryl Anne Zuckerman, Esq., Singer Frumento LLP

Applicability of NASD Rule 3030 to an associated person filing a membership application with the NASD to form a new broker/dealer.

December 06, 2001
Regulatory and Compliance Alerts (RCA)
Regulatory & Compliance Alert - Winter 2001
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December 01, 2001
Interpretive Letter
Interpretive Letter to Name Not Public

Applicability of NASD rules to a member's use of a translator for group retirement plan enrollment presentations.

November 26, 2001
Exemptive Letter
Name Not Public
Exemptive relief is granted based on the following considerations: 1) the contribution was inadvertent, de minimis, and was returned; and (2) the contribution was made to a candidate for public office who never had the opportunity to influence the award of municipal securities business (Candidate was not an elected official, was never elected to the office for which he was a candidate, and he died during the election campaign).
November 14, 2001
Exemptive Letter
William E. Floria, House of Securities Company

October 18, 2001

Mr. William E. Floria
President
House of Securities Company
12 West Church Street
Frederick, MD 21701

Re: Exemption Request from Fidelity Bonding Requirements

Dear Mr. Floria:

October 18, 2001
Interpretive Letter
Interpretive Letter to Mark W. Bolle, Raymond James Financial Services, Inc.

Rule 11210(a)(3) does not prohibit a firm from effecting the requirements of the provision electronically, but the firm is responsible for the accuracy and proper functioning of the computer program.

October 15, 2001
Interpretive Letter
Interpretive Letter to Kevin L. Palmer, WMA Securities, Inc.
During the period a registered representative is inactive for failure to complete the Regulatory Element, a member may pay the registered representative fees or commissions earned by the representative prior to the period of inactivity unless the member has a policy that prohibits it. However, a member may not pay the inactive registered representative commissions on securities sales that occur during the period that the registered representative is inactive.
October 02, 2001
Interpretive Letter
Interpretive Letter to Elliott R. Curzon, Esq., Dechert Price & Rhoads
A registered representative must register as an equity trader and pass the Series 55 qualification exam prior to trading distressed convertible debt securities (other than on a securities exchange).
September 27, 2001
Interpretive Letter
Interpretive Letter to David A. Genelly, Esq., Vanasco Genelly & MIller

An individual who processes transactions by communicating orders to the member’s clearing firm, which then calls or electronically communicates with the contra-side of the transaction, is not involved in the execution of transactions for purposes of Rule 1032(f) and thus is not required to be Series 55 registered.

September 25, 2001