<p>Scope of permissible functions of a Compliance Registered Operations Principal (CROP).<br />
</p>
<p>Mutual fund offeror may directly reimburse personal travel expenses of registered representatives that attend training and education meetings, provided appropriate records are maintained.<br/></p>
<p>Application of NASD Rule 2830(l)(5)(D) to sales contests involving sales personnel who perform marketing services.<br/></p>
<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 Select Sector SPDR Funds does not violate Rule 2830(c) and (g).<br/></p>
<p>Secondary market trading in streetTracks Series Funds does not violate NASD Rules 2830(c) and (g).<br />
</p>
<p>Payments by an investment adviser to broker-dealers in the form of rights to receive cash compensation upon the occurrence of specific corporate events (e.g., initial public offering of shares of the adviser) do not constitute "non-cash compensation" under NASD Rule 2830(l).<br/></p>
<p>Secondary market trading in ETF Advisors Trust shares does not violate NASD Rules 2830, 2110 or 2420.</p>
<p>Secondary market trading in Fresco Index Shares Funds would be consistent with the requirements of NASD Rules 2830(c) and (g).</p>
<p>Secondary market trading in Fidelity Nasdaq Composite Index Tracking Stock would be consistent with the requirements of NASD Rules 2110, 2420, 2830(c), (g), and (i), and Interpretive Material 2830-2.</p>
