Proposed Rule Change to Amend NASD Rule 3011 and Adopt New Related Interpretive Material, Specifically IM-3011-1 and IM-3011-2

NASD has filed with the Securities and Exchange Commission ("SEC" or "Commission") a proposed rule change to amend NASD Rule 3011 and adopt new related interpretive material ("IM"), specifically IM-3011-1 and IM-3011-2.  Proposed amendments to Rule 3011 would require each member to conduct the independent test of its anti-money laundering program on an annual basis, with the exception of certain types of firms, which would be allowed to test every two years.  Proposed IM-3011-1 would clarify the persons not considered to be independent for purposes of Rule 3011(c), and therefore not eligible to conduct the test.  Proposed IM-3011-2 would require a member to review and update, if necessary, the accuracy of the member's anti-money laundering compliance person information on a quarterly basis.