Interpretive Letters

Interpretive letters provide guidance on the staff's views as to the application of particular FINRA rules under specific circumstances. Members, associated persons, and their counsel should consider seeking further guidance regarding their own unique circumstances.

| Date | Title | Related Rule | Topic |
| --- | --- | --- | --- |
| Apr 26, 2023 | Interpretive Letter to Janet Dyer, National Financial Services, LLC | FINRA Rule 2210 - Communications with the Public | Negative Consent |
| Sep 01, 2020 | Interpretive Letter to Jason P. Ellison, Foreside Fund Services, LLC | FINRA Rule 2210 - Communications with the Public | Advertising Regulation, Related Performance |
| Jul 24, 2020 | Interpretive Letter to T. Douglas Hollowell, UBS Financial Services, Inc. | NASD Rule 11870 - Customer Account Transfer Contracts, NASD Rule 2110 - Standards of Commercial Honor and Principles of Trade | Negative Consent |
| Jun 16, 2020 | Interpretive letter to Michael Markunas, B. Riley FBR, Inc. and B. Riley Wealth Management, Inc. | FINRA Rule 1220 – Registration Categories | Investment Banking Referrals |
| May 30, 2019 | Interpretive letter to Jonathan D. Wiley, The Forbes Securities Group | CAB Rule 016(c) - Capital Acquisition Broker | Capital Acquisition Brokers |
| Jan 31, 2019 | Interpretive letter to Meredith F. Henning, Foreside | FINRA Rule 2210 - Communications with the Public | Advertising Regulation |
| Apr 16, 2018 | Interpretive letter to Joan E. Boros, Esq., Stradley Ronon Stevens & Young, LLP | FINRA Rule 2210 - Communications with the Public | Advertising Regulation, Related Performance |
| Dec 11, 2017 | Interpretive Letter to Lawrence Cohen, Gordon Rees Scully Mansukhani, LLP | FINRA Rule 5130 - Restrictions on the Purchase and Sale of Initial Equity Public Offerings | |
| Jun 12, 2017 | Interpretive Letter to Clair Pagnano, K&L Gates LLP | FINRA Rule 2210 - Communications with the Public | Related Performance, Advertising Regulation |
| May 09, 2017 | Interpretive Letter to Elliott R. Curzon, Dechert LLP | FINRA Rule 5131 – New Issue Allocations and Distributions | |
| Mar 22, 2016 | Interpretive Letter to Craig P. Hoffman, Esq., APM, American Retirement Association, Chris DeGrassi, National Tax-deferred Savings Association, and Richard K. Matta, Esq., Groom Law Group | FINRA Rule 2210 - Communications with the Public | Filing Requirements, Advertising Regulation |
| Feb 24, 2016 | Interpretive Letter to Marc Menchel, Menchel Consulting LLC | NASD Rule 1017 - Application for Approval of Change in Ownership, Control, or Business Operations | |
| May 12, 2015 | Interpretive Letter to Edward P. Macdonald, Hartford Funds Distributors, LLC | FINRA Rule 2210 - Communications with the Public | Related Performance, Advertising Regulation |
| Feb 20, 2015 | Interpretive Letter to Gregory J. Nowak, Pepper Hamilton LLP | FINRA Rule 5130 - Restrictions on the Purchase and Sale of Initial Equity Public Offerings | |
| Dec 01, 2014 | Interpretive Letter to Wallace W. Kunzman, Jr., Kunzman & Bollinger, Inc. | NASD Rule 1030 Series - Registration of Representatives | Business Development Company (BDC), Qualification Exams, Advertising Regulation, Direct Participation Programs (DPPs) |
| Apr 28, 2014 | Interpretive Letter to Russell D. Sacks, Shearman & Sterling LLP | NASD Rule 2711 - Research Analysts and Research Reports | Research Reports, Third Party Research, Advertising Regulation |
| Aug 26, 2013 | Interpretive Letter to Brian Sweeney, Trustmont Financial Group, Inc. | FINRA Rule 2111 - Suitability | Private Placements, Suitability |
| Apr 22, 2013 | Interpretive Letter to Bradley J. Swenson, ALPS Distributors, Inc. | FINRA Rule 2210 - Communications with the Public | Back testing, Advertising Regulation |
| Feb 08, 2013 | Interpretive Letter to Amy Natterson Kroll, Bingham McCutchen LLP | NASD Rule 2711 - Research Analysts and Research Reports | Qualification Exams, Third Party Research, Advertising Regulation, Research Analyst Rules |
| Feb 05, 2013 | Interpretive Letter to S. Kendrick Dunn, Pacific Select Distributors, Inc. | NASD Rule 3010 - Supervision | Qualification Exams, Supervision |
| Dec 21, 2012 | Interpretive Letter to Ira Hammerman, The Securities Industry and Financial Markets Association | FINRA Rule 11810 - Buy-In Procedures and Requirements | Customer Account Transfers |
| Nov 27, 2012 | Interpretive Letter to Name Not Public | NASD IM-2420-2 - Continuing Commissions Policy | |
| Jul 29, 2010 | Interpretive Letter to Michael Brennan | NASD Rule 1020 Series - Registration of Principals | Qualification Exams |
| Jun 09, 2010 | Interpretive Letter to Merrie Faye Witkin, The Depository Trust & Clearing Corporation | NASD Rule 11190 - Reconfirmation and Pricing Service Participants | |
| May 21, 2010 | Interpretive Letter to Claudia Crowley, NYSE Regulation, Inc. | FINRA Rules 7410-7470 (OATS) | |