Guidance
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Interpretive Letter
Entity should obtain a "no action" letter from the SEC before NASD Regulation will determine whether payment of non-transaction-based compensation from a member to a non-member for administrative and clerical services under a preferred alliance agreement would violate Rule 2420.
January 29, 1999
Interpretive Letter
Factors that may determine whether research personnel are required to be registered include their communications with customers, making of recommendations, accepting or executing orders for the purchase or sale of securities, and method of compensation.
January 27, 1999
Interpretive Letter
This letter grants an exception to the OATS requirements to submit Cancel/Replace Reports and Route Reports for modifications made by a trader to orders routed to an ECN for handling/execution. Customer modifications to orders are specifically excluded from the interpretation.
January 06, 1999
Interpretive Letter
IM-2420-2, the "Continuing Commissions Policy," does not apply to the receipt by a terminated broker/dealer of commissions generated by its former registered persons after they have transferred to a new firm. Rule 2420 would further apply to prohibit the receipt of the commissions by the non-member broker/dealer.
December 09, 1998
Interpretive Letter
IM-2420-2, the "Continuing Commissions Policy," does not apply to the receipt by a terminated broker/dealer of commissions generated by its former registered persons after they have transferred to a new firm. Rule 2420 would further apply to prohibit the receipt of the commissions by the non-member broker/dealer.
December 09, 1998
Interpretive Letter
Secondary market trading in Select Sector SPDR Funds does not violate Rule 2830(c) and (g).
December 07, 1998
Interpretive Letter
Broker/dealer should seek SEC interpretative advice regarding "override" payments to insurance company for securities transactions executed by registered representatives who are associated with both the broker/dealer and the insurance company.
December 07, 1998
Regulatory and Compliance Alerts (RCA)
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December 01, 1998
Interpretive Letter
Application of the OATS Rules to: partial executions, bunched orders, pegged orders, and negotiated orders.
October 26, 1998
Interpretive Letter
In a request for interpretive guidance, a member asks if NASD Rules prohibit a member from paying finders or referral fees to CPAs that are not registered as associated persons.
September 16, 1998
Regulatory and Compliance Alerts (RCA)
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September 01, 1998
Interpretive Letter
Application of Rule 2210 to the use of investment projections and marketing material when registered persons are conducting advisory services.
July 30, 1998
Interpretive Letter
NASD Rules 6950-6957 (OATS)
Clarification of application of the OATS rules.July 30, 1998
Interpretive Letter
A NASD member firm that is a proprietary trader and does not make markets is required to report orders in Nasdaq securities in compliance with OATS Rules 6951 through 6957.
July 17, 1998
Interpretive Letter
What is proper evidence of compliance with clock synchronization requirements pursuant to NASD Rule 6953?
July 02, 1998
Interpretive Letter
Under Rule 2710, a broker/dealer may pay finder's fees to a joint venture for the referral of issuers that are potential corporate finance clients. If the joint venture is not required to be registered as a broker/dealer, such payments would not violate Rule 2420.
June 18, 1998
Interpretive Letter
The use of a combined name on certain public communications to reflect a recent merger of two member firms and create a single global "brand," would not violate the requirement of Rule 2210 that public communications include the name of the member firm.
June 08, 1998
Regulatory and Compliance Alerts (RCA)
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June 01, 1998
Exemptive Letter
May 29, 1998
Mr. Kenneth W. Perlman
General Counsel
Mayer & Schweitzer, Inc.
111 Pavonia Avenue East
Jersey City, New Jersey 07310
Re: Exemption Pursuant to NASD Rule 2320(g)(2)
Dear Mr. Perlman:
May 29, 1998
Interpretive Letter
Unregistered associated persons may not routinely take customer orders during periods of peak telephone call volume.
May 27, 1998
Interpretive Letter
The use of a member name without the corporate modifier “L.L.C.” on certain materials adequately denotes the name of the member and would not violate the requirement of NASD Rule 2210 (f)(2) to include a member name.
May 11, 1998
Interpretive Letter
A registered representative presently licensed with a member providing telemarketing services, under certain conditions, would not be required to also be registered with a client member.
April 22, 1998
Interpretive Letter
The provisions of the three quote rule apply to transactions in foreign securities executed on a foreign exchange for member customers.
April 09, 1998
Interpretive Letter
A broker/dealer is not required to register as branch offices under Rule 3010(g) non-public office locations where existing customers can use computer terminals to access their accounts and enter orders.
March 16, 1998
Regulatory and Compliance Alerts (RCA)
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March 01, 1998