Direct Purchases and Bank Loans as Alternatives to Public Financing in the Municipal Securities Market
REQUEST FOR COMMENT
Rule Harmonization
SUGGESTED ROUTING
KEY TOPICS
Corporate Financing Legal & Compliance
Registration
Senior Management
Branch Office
Initial Public Offering
Office of Supervisory Jurisdiction
Registration
Rule 2711 (Research Analysts and
Research Reports)
Rule 3010 (Supervision)
Rule Harmonization
As prepared for delivery.
I would like to discuss with you today the important question of the appropriate standard of care for brokers and dealers or, more directly, whether the time has come to require broker-dealers, when recommending a security or strategy to retail investors, to ensure that the recommendation is in the “best interest” of the investor.
A “best interest” or “fiduciary”
The use of related performance information in institutional communications, subject to specific conditions, is consistent with the applicable standards of FINRA Rule 2210.
GUIDANCE
Life Settlements
SUGGESTED ROUTING
KEY TOPICS
Internal Audit
Legal and Compliance
Retail
Senior Management
Variable Life Settlements
Variable Insurance Policies
Suitability
Best Execution
Rule 3010
Executive Summary
Sales of existing life insurance policies to third parties—often
referred to as "life settlements"—have grown exponentially in
recent years, and
GUIDANCE
Correspondence
SUGGESTED ROUTING
KEY TOPICS
Advertising
Executive Representatives
Legal & Compliance
Registered Representatives
Senior Management
Correspondence
Rule 2211
Executive Summary
On July 26, 2006, the Securities and Exchange Commission (SEC)
approved amendments to NASD Rule 2211, which governs NASD
member institutional sales material and
Proposed Rule Change to Adopt FINRA Rule 11000 Series (Uniform Practice Code) in the Consolidated FINRA Rulebook
INFORMATIONAL
SUGGESTED ROUTING
KEY TOPICS
Executive Representatives
Senior Management
NASD Board of Governors
Executive Summary
The Annual Meeting of NASD members will be held on February 3,
2006.
The formal notice of the meeting, including the precise time and
location, will be mailed on or about December 29, 2005. The
individuals nominated by the NASD National
The NASD, through its wholly owned subsidiary, NASD Regulation, Inc., has filed with the SEC a proposed rule change to adopt NASD Rule 3090, to: (1) require NASD members to promptly obtain and implement a duplicate statement instruction whenever they have actual knowledge that an Association or American Stock Exchange employee has a financial interest in, or controls trading in, an account; (2)
