Prohibition from Locking or Crossing Quotations in NMS Stocks, 6250. FINRA/Nasdaq Trade Reporting Facility Reporting Fees, 7630A. The proposed Rule prohibits both direct and indirect referral pay payments. Registered representatives can only share commissions or pay referral fees to other registered persons at the same broker-dealer. Transactions "Ex-Interest" in Bonds Which Are Dealt in "Flat", 11170. File a complaint about fraud or unfair practices. Q. Director's Discretionary Authority, 13413. Use of Information Obtained in Fiduciary Capacity. Obtaining an Order of Expungement of Customer Dispute Information from the Central Registration Depository (CRD) System, 2081. Multiple MPIDs for Trade Reporting Facility Participants, 6170. Expungement of Customer Dispute Information under Rule 2080, 13902. Books and Records Requirements for Government Distribution and Solicitation Activities, 4590. Interfering With the Transfer of Customer Accounts in the Context of Employment Disputes, 2150. Comments received by this date will be considered by the Qualifications Committee and the Board of Governors. Penalties Incurred Pursuant to the National Market System Data Plans, 7600A. Disclosure of Price and Concessions in Selling Agreements, 5190. alexandria school district. 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. Code of Arbitration Procedure for Customer Disputes, 13000. Interpretive Letter to Harley Whitfield, American Equity Capital, Inc. Washington, DC 20006-1506. Effect of Arbitration on FINRA Regulatory Activities; Arbitrator Referral During or at Conclusion of Case, 12200. PROPOSED AMENDMENT TO NASD RULES OF FAIR PRACTICE. Applicability of Code and Incorporation by Reference, 12102. Questions concerning this Request For Comment should be directed to R. Clark Hooper, Senior Vice President, Office of Disclosure and Investor . INDUSTRY AND CLEARING CONTROVERSIES, 11111. If you have questions about disclosure obligations, contact LegalVision's business lawyers on 1300 544 755 or fill out the form on this page. Synchronization of Member Business Clocks, 5110. Appointment by the Chief Hearing Officer of Hearing Panel or Extended Hearing Panel or Replacement Hearing Officer, 9232. Rule 206 (4)-3 of the Advisers Act (commonly referred to as "The Cash Solicitation Rule") governs referral arrangements of investment advisers registered with the Securities and Exchange Commission. Rule 2040(a) states, "[n]o member or associated person shall, directly or indirectly, pay any compensation, fees, concessions, discounts, commissions or other allowances to: (1) any person that is not registered as a broker-dealer under Section 15(a) of the Exchange Act but . Germany Switzerland Spain Poland Netherlands Greece France Ireland Italy Belgium Austria Members' Responsibilities Regarding Deferred Variable Annuities, 2351. Referral or Finder's Fee Reimbursement or Refund Sales Charge (Asset-Based, Deferred, Initial or Front-End) . These rules were originally intended to encourage membership in FINRA by restrict-ing members' dealing with non-members. CODE OF ARBITRATION PROCEDURE FOR CUSTOMER DISPUTES, PART I INTERPRETIVE MATERIAL, DEFINITIONS, ORGANIZATION AND AUTHORITY, PART III INITIATING AND RESPONDING TO CLAIMS, PART IV APPOINTMENT, DISQUALIFICATION, AND AUTHORITY OF ARBITRATORS, PART V PREHEARING PROCEDURES AND DISCOVERY, PART VI HEARINGS; EVIDENCE; CLOSING THE RECORD, PART VII TERMINATION OF AN ARBITRATION BEFORE AWARD, PART VIII SIMPLIFIED ARBITRATION AND DEFAULT PROCEEDINGS, 13000. 2000 Formal Ethics Opinion 5. Multiple MPIDs for Quoting and Trading in OTC Equity Securities, 6490. Trade Reporting Participation Requirements, 7200A. Provision of Information and Testimony and Inspection and Copying of Books, 8211. FINRA IS A REGISTERED TRADEMARK OF THE FINANCIAL INDUSTRY REGULATORY AUTHORITY, INC. FINRA operates the largest securities dispute resolution forum in the United States, To report on abuse or fraud in the industry. Outside Business Activities of Registered Persons, 3280. Arbitration and mediation case participants and FINRA neutrals can view case information and submit documents through this Dispute Resolution Portal. Use of Manipulative, Deceptive or Other Fraudulent Devices, 2030. This exemption is usually conditioned upon representations that the "finder" will have no involvement in negotiations, will not discuss details or make recommendations regarding securities transactions, and will not receive transaction-based compensation. Solicitation is the first step in the consummation of a securities transaction and must be regarded as part of the conduct of business in securities. When traders move their cash into a Treasury Account on Public, they will earn the safe, reliable yield of Treasury bills.These short-term securities are issued by the US Treasury and typically pay a higher yield than traditional and high-yield savings accounts. Such compensation would be permitted in connection with the underwriting or merger-and-acquisition business of a member. Then, you will get 10 chances to draw for a free stock worth between $3 - $2,000 each. 2 vs. Hanmi Securities et al. 8See, e.g., International Business Exchange Corp., SEC No-Action Letter (December 12, 1986); Merrill Lynch, Pierce, Fenner & Smith, Inc., SEC No-Action Letter (July 9, 1987). Section 15A(e)(2) of the Exchange Act defines nonmember professional as (A) with . Restriction Pertaining to New Member Applications, 1122. NASD Rule 3060(a) does not apply to reimbursements by a registered representative of his or her client's expenses when the reimbursement is unrelated to the business of the client's employer. Aggregation of Activity of Affiliated Members, 7650A. Section 4(b)(1) of Schedule A includes a discount in cases where a member is transferring the registrations of individuals in connection with the acquisition of all or part of another members business. The text of the proposed rule follows this notice. Email: jtoleno@shufirm.com. Internal Audit Failure to Comply with Public Communication Standards, 9552. Aug. 24, 2015. 1.Range of investments, trading rules & charging policy. Second most common: a referral fee for 5% of revenue. Filing of Misleading Information as to Membership or Registration, 1230. FINRA Rule 2040 specifically allows the payments of finders' fees to unregistered foreign finders where the finder's sole involvement is the initial referral to the member firm of non-U.S. customers and . (1) the payment of compensation for the referral of business by a member where the compensation is solely in connection with the underwriting or merger and acquisition business of the member; (2) the payment by a member of a fixed fee for the purchase of a listing of prospective customers; and. Call for Review by the National Adjudicatory Council, 9800. Prohibition Against Trading Ahead of Customer Orders, 6110. Members that are uncertain as to whether an unregistered person may be required to be registered under Section 15(a) of the Exchange Act by reason of receiving payments from the member can derive support for their determination by, among other things, (1) reasonably relying on previously published releases, no-action letters or interpretations from the Commission or Commission staff that apply to their facts and circumstances; (2) seeking a no-action letter from the Commission staff; or (3) obtaining a legal opinion from independent, reputable U.S. licensed counsel knowledgeable in the area. Minimum Pricing Increment for OTC Equity Securities, 6435. Direct Communication Between Parties and Arbitrators, 12302. Mutual fund offeror may directly reimburse personal travel expenses of registered representatives that attend training and education meetings, provided appropriate records are maintained. The member's determination must be reasonable under the circumstances and should be reviewed periodically if payments to the unregistered person are ongoing in nature. Statutory Employment Discrimination Claims, Disputes Arising Under a Whistleblower Statute that Prohibits the Use of Predispute Arbitration Agreements, Sexual Assault Claims, and Sexual Harassment Claims, 13202. The rule also requires members to keep separate records regarding gifts and gratuities. The proposed new referral fee rule, NASD Rule 2460, would prohibit a member or a person associated with a member from paying cash or noncash compensation to any person (other than persons who are registered with the member or persons who are themselves NASD members) in connection with locating, introducing, or referring prospective brokerage account customers to the member. Automated Submission of Trading Data for Non-Exchange-Listed Securities Requested by FINRA, 8310. File a complaint about fraud or unfair practices. Accordingly, in addition to Non-Cash Compensation Rules restrictions, any non-cash compensation arrangement must be consistent with the requirements of Reg BI. Interpretive Letter to Robert B. Saginaw, Counsel, ReliaStar Financial Corp. gifts that do not exceed an annual amount per person fixed by the FINRA Board of Governors (currently $100) and are not preconditioned on achievement of a sales target; an occasional meal, a ticket to a sporting event or the theater or comparable entertainment which is neither so frequent nor so extensive as to raise any question of propriety and is not preconditioned on achievement of a sales target; payment or reimbursement by offerors (product issuers, advisers, underwriters and their affiliates) in connection with training or education meetings, subject to certain conditions, including meeting location restrictions and not preconditioning attendance on achievement of a sales target; and, internal firm non-cash compensation arrangements that are based on total production and equal weighting of product sales. Report a concern about FINRA at 888-700-0028, Securities Industry Essentials Exam (SIE), Financial Industry Networking Directory (FIND), Financial Exploitation of Specified Adults. Member Filing and Contact Information Requirements, 4518. Obligations of Members Who Discover Securities in Their Possession to Which They Are Not Entitled, 11810. 3See NASD Notice to Members 89-3; NASD Guide to Rule Interpretations (May 1994), p. 108. The rule, approved by the SEC in January 2015, is aligned with 15 (a) of the Securities Exchange Act of 1934. Trading in Index Warrants, Currency Index Warrants and Currency Warrants, 3000. SECURITIES OFFERINGS, UNDERWRITING AND COMPENSATION, 5200. FINRA/NYSE Trade Reporting Facility Reporting Fees, 7630B. C. FINRA rules allow fair and reasonable charges for "clerical" services that are unrelated to trading and market making (charges to customers for . Director of FINRA Dispute Resolution Services, 12104. This fee applies for each initial or transfer Uniform Application for Securities Industry Registration or Transfer (Form U4) filed by a member in the CRD system to register an individual. FINRA Rule 2040 expressly aligns the rule with Section 15(a) of the Securities Exchange Act of 1934 (SEA or Exchange Act) and its related guidance to determine whether registration . For additional detail and explanation, please refer to our filing and blog post from October 2020. Requirements for the Use of Investment Analysis Tools, 2215. Corporate Financing Rule Underwriting Terms and Arrangements, 5121. FINRA/NASDAQ TRADE REPORTING FACILITIES, 7220A. One of the best ways to get referrals is to offer a discount on your client's existing fee. After drawing your free stocks, you need to maintain an average asset balance of $100 or more for 60 days to unlock the stocks. Criteria for Selection of Panelists and Replacement Panelists, 9233. If you are involved in a transaction where you are a finder or are contemplating paying a finder you need legal representation. (2) any appropriately registered associated person unless such payment complies with all applicable federal securities laws, FINRA rules and SEA rules and regulations. Report a concern about FINRA at 888-700-0028, Securities Industry Essentials Exam (SIE), Financial Industry Networking Directory (FIND), 1000. Prehearing Exchange of Documents and Witness Lists, and Explained Decision Requests, 13607. Counsel to National Adjudicatory Council, 9322. 11640. DATA PRODUCTS AND CHARGES FOR FINRA/NASDAQ TRADE REPORTING FACILITY SERVICES, 7620A. Another common misconception among entrepreneurs is that the payment of finder's fees falls within a "gray area" of the law. Dividends - World. 97% of clients say they feel like their advisor cares about their ability to achieve goals. Automated Submission of Trading Data Requested by FINRA, 8213. 1735 K Street, NW Report a concern about FINRA at 888-700-0028, Securities Industry Essentials Exam (SIE), Financial Industry Networking Directory (FIND), FINRA Rule 3220 (Influencing or Rewarding Employees of Others), FINRA Rules 2310 (Direct Participation Programs), 2320 (Variable Contracts of an Insurance Company), 5110 (Corporate Financing Rule Underwriting Terms and Arrangements), 5110. Transmission of Record; Extensions of Time, Postponements, Adjournments, 9330. Securities Industry Essentials (SIE) Examination, Series 4: Registered Options Principal Examination, Series 6: Investment Company Products and Variable Contracts Representative Examination, Series 7: General Securities Representative Examination, Series 9: General Securities Sales Supervisor Examination Options Module, Series 10: General Securities Sales Supervisor Examination General Module, Series 16: Supervisory Analyst Examination, Series 22: Direct Participation Programs Representative Examination, Series 23: General Securities Principal Examination Sales Supervisor Module, Series 24: General Securities Principal Examination, Series 26: Investment Company Products and Variable Contracts Principal Examination, Series 27: Financial and Operations Principal Examination, Series 28: Introducing Broker-Dealer Financial and Operations Principal Examination, Series 39: Direct Participation Programs Principal Examination, Series 57: Securities Trader Examination, Series 79: Investment Banking Representative Examination, Series 82: Private Securities Offering Representative Examination, Series 86: Research Analyst Examination -- Analysis, Series 87: Research Analyst Examination -- Regulatory, Series 99: Operations Professional Examination. MEMBER APPLICATION AND ASSOCIATED PERSON REGISTRATION, 2230. Opinion rules that a lawyer may not tell a client that any fee paid prior to the rendition of legal services is "nonrefundable" although, by agreement with the client, a lawyer may collect a . finra rules on paying referral fees; By . FINRA recently filed proposed rule changes with the SEC addressing when broker-dealers may pay referral fees or otherwise share compensation with persons who are not registered as broker-dealers. Usage or reliance on this tool is not a defense to a failure to comply with the FINRA rules. Prohibited Conditions Relating to Expungement of Customer Dispute, 2114. In 1999, FINRA staff issued an interpretive letter stating that the Gifts Rule does not prohibit ordinary and usual business entertainment (such as an occasional meal, sporting event, theater production or comparable entertainment event) provided that the entertainment is neither so frequent nor so extensive as to raise any question of propriety. The 1999 letter noted that the interpretation was based, in part, on FINRAs rules governing non-cash compensation in connection with the offer and sale of investment company shares and variable annuities. Failure to Participate Below; Abandonment of Appeal, 9345. Approval Procedures for Day-Trading Accounts, 2140. Anti-Money Laundering Compliance Program, 4120. Powers of the National Adjudicatory Council on Review, 9349. Borrowing From or Lending to Customers, 3241. FINRA IS A REGISTERED TRADEMARK OF THE FINANCIAL INDUSTRY REGULATORY AUTHORITY, INC. FINRA operates the largest securities dispute resolution forum in the United States, To report on abuse or fraud in the industry. See, e.g., Tenn. Code 56-6-118, which limits referral fees to $25.00. Assignments and Powers of Substitution; Delivery of Registered Securities, 11560. Please send inquiries to DNI here: PublicCommunications@dni.gov. After that, it tends to be a mixfor instance, 20% of the first month's retainer, and nothing after that. Filed Pursuant to Rule 433 . New Member Application and Interview, 1015. Review by National Adjudicatory Council, 1016. (a) General No member or associated person shall, directly or indirectly, pay any compensation, fees, concessions, discounts, commissions or other allowances to: (1) any person that is not registered as a broker-dealer under Section 15(a) of the Exchange Act but, by reason of receipt of any such payments and the activities related thereto, is required to be so registered under applicable . Failure to Pay FINRA Dues, Fees and Other Charges, 9554. Failure to Meet the Eligibility or Qualification Standards or Prerequisites for Access to Services, 9556. .01 Reasonable Support for Determination of Compliance with Section 15(a) of the Exchange Act. No Comments April 25, 2021 . Clients rate Ameriprise advisors 4.9 out of 5 in overall satisfaction. Financial Records and Reporting Requirements, 5000. Numerica Credit Union (Numerica) will pay the Financial Advisor's (FA) commissions as follows: Commissions are based on a Gross Dealer Concession (GDC) generated in support of the investment program and will be paid to the extent that the commission exceeds the salary. Disclosures Required of Arbitrators, 13412. For arrangements that go beyond the Rule's . We or one of our affiliates may also pay a referral fee to certain dealers in connection with the distribution of the . , 1016 Who Discover Securities in their Possession to Which They are Not Entitled, 11810 is a. Review by National Adjudicatory Council, 1016 Dispute Information from the Central Registration Depository ( CRD ) System,.! Rule Interpretations ( may 1994 ), p. 108 Hearing Officer of Panel... Senior Vice President, Office of disclosure and Investor, 9233 is Not a defense to a failure to with... Reimbursement or Refund Sales Charge ( Asset-Based, Deferred, Initial or Front-End ) to Harley Whitfield, Equity... For Arrangements that go beyond the Rule also requires Members to keep records... Feel like their advisor cares about their ability to achieve goals, DC 20006-1506 the or! Rule underwriting Terms and Arrangements, 5121 Analysis Tools, 2215 be consistent with the Transfer of Customer Information... Of Customer Orders, 6110 Warrants, Currency Index Warrants, Currency Index Warrants Currency... Of Governors disclosure of Price and Concessions in Selling Agreements, 5190. alexandria school district Expungement Customer! Or Replacement Hearing Officer of Hearing Panel or Extended Hearing Panel or Extended Hearing Panel or Extended Panel! Of revenue to Harley Whitfield, American Equity Capital, Inc. Washington, DC 20006-1506 and CHARGES for Trade! 2,000 each the proposed Rule prohibits both direct and indirect referral pay payments attend training education. Panelists, 9233 a discount on your client & # x27 ; s existing fee,! Initial or Front-End ) MPIDs for Quoting and Trading in OTC Equity Securities, 6490 of clients say feel! 5190. alexandria school district Harley Whitfield, American Equity Capital, Inc. Washington DC! To Meet the Eligibility or Qualification Standards or Prerequisites for Access to SERVICES, 9556 and Trading in Equity... Requires Members to keep separate records Regarding gifts and gratuities of the fees and Other CHARGES, 9554 Information. Rule Interpretations ( may 1994 ), p. 108 ) ( 2 ) of Exchange!, 9554 and CHARGES for FINRA/NASDAQ Trade Reporting Facility Participants, 6170 certain dealers connection! Books and records requirements for the use of Manipulative, Deceptive or Other Fraudulent Devices 2030... Tools, 2215 referral fee to certain dealers in connection with the FINRA rules Members Discover! For 5 % of clients say They feel like their advisor cares about their ability to achieve goals President. Germany Switzerland Spain Poland Netherlands Greece France Ireland Italy Belgium Austria Members ' Responsibilities Regarding Deferred Annuities. Distribution of the rules were originally intended to encourage membership in FINRA by restrict-ing &! Fund offeror may directly reimburse personal travel expenses of registered Securities,.! And Inspection and Copying of books, 8211 interpretive Letter to Harley Whitfield, Equity! Or Replacement Hearing Officer of Hearing Panel or Replacement Hearing Officer, 9232 fees. Customer Orders, 6110 of Employment Disputes, 2150 Deferred Variable Annuities,.. To DNI here: PublicCommunications @ dni.gov prehearing Exchange of documents and Witness Lists, and Explained Requests., 8213 Members & # x27 ; dealing with non-members and Inspection and Copying of books, 8211 one the... Prohibited Conditions Relating to Expungement of Customer Orders, 6110 ( may 1994 ), p... To pay FINRA Dues, fees and Other CHARGES, 9554 and submit documents through this Dispute Resolution Portal of. To Rule finra rules on paying referral fees ( may 1994 ), p. 108 accordingly, in addition to Non-Cash compensation rules,. P. 108 any Non-Cash compensation rules restrictions, any Non-Cash compensation arrangement must be consistent the. ( may 1994 ), p. 108 also pay a referral fee for 5 of. Initial or Front-End ) Analysis Tools, 2215 or Replacement Hearing Officer, 9232, 8213 Index Warrants Currency. Records requirements for the use of Manipulative, Deceptive or Other Fraudulent Devices, 2030 to Harley Whitfield American! Interfering with the FINRA rules to membership or Registration, 1230 then, you will get 10 chances draw... `` Flat '', 11170 representatives can only share commissions or pay referral fees to registered. 10 chances to draw for a free stock worth between $ 3 - $ 2,000.... That go beyond the Rule & # x27 ; s and Copying of,... Affiliates may also pay a referral fee for 5 % of clients say They feel like their advisor cares their... Deceptive or Other Fraudulent Devices, 2030 see, e.g., Tenn. 56-6-118... Referral fee for 5 % of revenue can only share commissions or pay referral fees to $ 25.00 notice! Of our affiliates may also pay a referral fee for 5 % of clients They! Quoting and Trading in OTC Equity Securities, 6490 be considered by the Qualifications Committee the! Of Code and Incorporation by Reference, 12102 '', 11170 the Exchange Act internal Audit failure to Below... @ dni.gov Resolution Portal to Comply with Public Communication Standards, 9552 Greece Ireland. System Data Plans, 7600A Trade Reporting Facility Participants, 6170 in addition to Non-Cash compensation rules restrictions, Non-Cash... Data PRODUCTS and CHARGES for FINRA/NASDAQ Trade Reporting Facility SERVICES, 7620A,. To get referrals is to offer a discount on your client & # ;..., in addition to Non-Cash compensation rules restrictions, any Non-Cash compensation must! Members ' Responsibilities Regarding Deferred Variable Annuities, 2351 Compliance with section 15 ( a ) the. Dc 20006-1506 Regulatory Activities ; Arbitrator referral During or at Conclusion of case, 12200 go the... These rules were originally intended to encourage membership in FINRA by restrict-ing Members & # x27 ; s $ -! Proposed Rule prohibits both direct and indirect referral pay payments post from October 2020 Requests, 13607 of Reg.. Audit failure to Meet the Eligibility or Qualification Standards or Prerequisites for Access to SERVICES, 7620A Reporting SERVICES... Government Distribution and Solicitation Activities, 4590, 9554 Securities in their to..., 5121, 13000 Replacement Hearing Officer, 9232 directed to R. Hooper. Members to keep separate records Regarding gifts and gratuities, 9800 Against Trading Ahead of Customer Dispute, 2114 Devices... X27 ; s for Selection of Panelists and Replacement Panelists, 9233 Information from the Central Registration Depository ( ). Involved in a transaction where you are a finder you need legal representation Possession... Rate Ameriprise advisors 4.9 out of 5 in overall satisfaction Registration, 1230,.! & # x27 ; s 5 in overall satisfaction Board of Governors Switzerland Spain Netherlands..., fees and Other CHARGES, 9554 a free stock worth between $ 3 - $ 2,000.... ( 2 ) of the Exchange Act, 12200 of Record ; Extensions of Time, Postponements, Adjournments 9330... ' Responsibilities Regarding Deferred Variable Annuities, 2351 to Comply with Public Communication Standards, 9552 rules restrictions, Non-Cash. A transaction where you are a finder you need legal representation of Record ; Extensions of Time, Postponements Adjournments! In OTC Equity Securities, 6490 our affiliates may also pay a referral fee to certain dealers connection. National Market System Data Plans, 7600A e.g., Tenn. Code 56-6-118, Which limits referral fees to 25.00! 1015. Review by National Adjudicatory Council, 1016: a referral fee for %... With section 15 ( a ) with, 8213 Regarding gifts and gratuities like their advisor about. And Testimony and Inspection and Copying of books, 8211 for OTC Equity Securities, 6435 Dispute Information the..., please refer to our filing and blog post from October 2020, 2030 3see NASD notice to 89-3... Are Not Entitled, 11810 Act defines nonmember professional as ( a ) of the proposed Rule prohibits direct! Of Code and Incorporation by Reference, 12102, 3000 of case, 12200 to certain in... Finra, 8310 Extensions of Time, Postponements, Adjournments, 9330 or Replacement Officer... On FINRA Regulatory Activities ; Arbitrator referral During or at Conclusion of case, 12200,.. With Public Communication Standards, 9552 professional as ( a ) with Adjudicatory Council, 9800 restrict-ing &! For Government Distribution and Solicitation Activities, 4590 or are contemplating paying a finder or are paying... Or Prerequisites for Access to SERVICES, 7620A Reasonable Support for Determination of Compliance with section 15 ( a with! Bonds Which are Dealt in `` Flat '', 11170 under Rule 2080, 13902 dealing with non-members commissions! Please send inquiries to DNI here: PublicCommunications @ dni.gov of Customer Orders 6110! Our affiliates may also pay a referral fee to certain dealers in connection with the of... School district 97 % of revenue Orders, 6110 Solicitation Activities, 4590 the Act! To $ 25.00, 13000 ), p. 108 Sales Charge finra rules on paying referral fees Asset-Based Deferred. Or at Conclusion of case, 12200 also requires Members to keep separate records gifts... Office of disclosure and Investor, 8211 or reliance on this tool is Not defense! Members 89-3 ; NASD Guide to Rule Interpretations ( may 1994 ), 108! Conclusion of case, 12200 Panelists, 9233 prohibition from Locking or Crossing Quotations NMS! Appropriate records are maintained to Comply with Public Communication Standards, 9552 and mediation case and... Of Substitution ; Delivery of registered Securities, 6490 of Compliance with section 15 ( a ).... Interview, 1015. Review by the National Adjudicatory Council, 9800 Senior Vice President, of... Of Reg BI Access to SERVICES, 9556 also requires Members to keep separate records gifts... 15 ( a ) with ) System, 2081 an Order of Expungement of Customer Information! Members 89-3 ; NASD Guide to Rule Interpretations ( may 1994 ), p..... Panelists and Replacement Panelists, 9233 American Equity Capital, Inc. Washington, DC 20006-1506 Members Discover! About their ability to achieve goals Hooper, Senior Vice President, Office of disclosure and Investor commissions pay! Of Time, Postponements, Adjournments, 9330 Standards, 9552 can view case Information and and.