<p align="left">Reminder that offerors may not pay for golf outings, tours or other forms of entertainment while at a meeting it sponsors for the purpose of training or education. This letter was sent by NASD Regulation to a number of members that manufacture and sponsor variable and investment company products and to certain trade associations.</p>
<p>Secondary market trading in streetTracks Series Funds does not violate NASD Rules 2830(c) and (g).<br />
</p>
<p>If a member transmits orders to buy and sell TRACE-eligible securities to other broker-dealers for the benefit of various proprietary accounts of foreign affiliates of the member, the member is acting as agent and must report the transactions under Rule 6230.</p>
September 25, 2006On September 14, 2006, NASD filed a proposed rule change (SR-NASD-2006-108) to establish a new Trade Reporting Facility in conjunction with the National Stock Exchange ("NSX") that would provide members another mechanism for reporting trades in Nasdaq-listed equity securities effected otherwise than on an exchange.NASD is issuing this OATS Report to inform members that
The request for exemptive relief is denied. You represent that Firm had established comprehensive and detailed procedures which included the requirement to pre-clear political contributions. Indeed, the firm’s procedures were attached to your exemption request as "Attachment No. 2," and they require that "all public finance employees" of the firm obtain prior approval of political contributions. The CEO did not follow the firm’s established procedures. This lapse by a senior official is significant and leads us to conclude that the request for an exemption should be denied.
Securities Industry/Regulatory Council on Continuing Education Issues Firm Element Advisory Update
INFORMATIONAL
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NASD® has taken disciplinary actions against the following firms and individuals for violations of NASD rules; federal securities laws, rules and regulations; and the rules of the Municipal Securities Rulemaking Board (MSRB).
