Staff grants exemption from the Short Sale Rule for certain transactions executed through a member's passively-priced trading system.
April 3, 2007
Mr. Louis J. Karcher
Principal & Chief Compliance Officer
Pipeline Trading Systems LLC
60 East 42nd Street, Suite 624
New York, NY 10165-0006
Re: NASD Rule 5100: Request for Exemptive Relief
Dear Mr. Karcher:
This is in
Effective Date: June 12, 1998
SUGGESTED ROUTING
Senior Management
Institutional
Internal Audit
Legal & Compliance
Options
Systems
Trading
Executive Summary
On June 12, 1998, the Securities and Exchange Commission (SEC) approved amendments to National Association of
Establishing "firewalls" that prevent the execution of short sales in securities not on a member's "Easy to Borrow" list would be consistent with Rule 3370(b). A member that only conducts a review after a short sale order has been executed to ensure that the security is on the "Easy to Borrow" list would not be in compliance with Rule 3370(b).
NASD has filed with the SEC a proposed rule change to amend NASD Rule 3360 to change references from "SEC Rule 3b-3" to "SEC Rule 200," thereby conforming the rule language in Rule 3360 in light of the SEC’s new short sale regulation, Regulation SHO.
GUIDANCE
Options Position and Exercise Limits
SUGGESTED ROUTING
KEY TOPICS
Institutional
Legal & Compliance
Options
Senior management
Trading
Training
Exercise Limits
Hedge Exemption
Options
Position Limits
Rule 2860
Executive Summary
On March 30, 2005, NASD filed for immediate effectiveness with
the Securities and Exchange Commission (SEC) amendments to
Proposed Rule Change to Adopt FINRA Rule 4320 (Short Sale Delivery Requirements) in the Consolidated FINRA Rulebook
FINRA Modifies the Process for Firms to Designate Their Allocation Methodology for Options Exercise Assignment Notices
<p>NASD members must make an affirmative determination for all short sales prior to executing the sale (absent an exemption), including short positions not carried overnight.</p>
Dear FINRA, First of all, I am the owner of my own money. The regulators have no right AT ALL to make me go through certain process to make my own investment decisions. Leveraged and inverse funds are important to my investment strategies. I put part of my investment fund in TQQQ and UPRO on a regular basis as a long-term bet for the positive outlook of US economy. People would argue that TQQQ or
Financial Industry Regulatory Authority, Inc. ("FINRA") (f/k/a National Association of Securities Dealers, Inc. ("NASD")) is filing with the Securities and Exchange Commission ("SEC" or "Commission") a proposed rule change to amend NASD Rule 3210 (Short Sale Delivery Requirements) in light of the amendments to Rule 203 of Regulation SHO under the Act.
