Regulatory Comment Letters

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05/03/13 NASAA Letter to SEC on Arbitration and Class Action Waivers
04/10/13 NASAA Comments on SEC Regulatory Initiatives under the Jumpstart Our Business Startups Act: Title IV – Small Company Capital Formation
03/05/13 NASAA comment letter to FINRA re: FINRA Rule Proposal 13-02 – Request for Comment on Recruitment Compensation Practices
2/15/13 NASAA Comment Letter to the SEC regarding Release No. 34-68700, File Number SR-FINRA-2013-002, a proposal to require all member firms and associated persons to include a prominent description of and link to their specific BrokerCheck page on their web sites, social media pages, and any comparable internet presence.

 
02/07/13

NASAA Comment Letter to the SEC regarding Release No. 34-68632; File No. SR-FINRA-2013-003 on the Proposal to Revise the definition of “Public Arbitrator”

10/03/12 NASAA Comment Letter to SEC Regarding Eliminating the Prohibition Against General Solicitation and General Advertising in Rule 506 and Rule 144A
08/20/12 NASAA Comment Letter to CFPB Regarding Senior Financial Exploitation
08/15/12 NASAA Comment Letter to SEC Regarding Regulation D Rule 506 and General Solicitation
07/03/12 Initial NASAA Comments to SEC re JOBS Act Rulemaking
06/25/12 NASAA Comment Letter to the CFPB in response to Docket No. CFPB-2012-0017, Request for Information Regarding Scope, Methods, and Data Sources for Conducting Study of Pre-Dispute Arbitration Agreements
05/21/12 NASAA comment letter to FINRA in response to Regulatory Notice 12-18
04/27/12 NASAA comment letter to FINRA in response to Regulatory Notice 12-10
04/23/12 NASAA comment letter to the SEC in response to FINRA’s Partial Amendment of SR-FINRA 2011-057. Release No. 34-66203
04/11/12 NASAA comment letter to FINRA in response to Regulatory Notice 12-14 
11/18/11 NASAA comment letter to FINRA in response to Regulatory Notice 11-44 regarding DPP offerings
11/17/11 NASAA comment letter to FINRA regarding private placements of securities, File No. SR-FINRA-2011-057
07/25/11 NASAA Comment Letter to SEC Regarding Disqualification of Felons and Other “Bad Actors” From Rule 506 Offerings. Release No. 33-9211, File No. S7-21-11
07/11/11 NASAA comment letter to the SEC regarding Release No. IA-3198; File No. S7-17-11 on Investment Adviser Performance Compensation
06/21/11 NASAA comment letter to the SEC in response to the Section 917 study of effective existing investor education programs; File number 4-626, Release number 34-64306
05/02/11 NASAA Comment letter to the SEC in response to FINRA’s proposal to implement a registration requirement for operations professionals. SEC file number SR-FINRA-2011-013
03/15/11 NASAA comment letter to SEC regarding permanent rule for registration of municipal advisors, SEC File Number S7-45-10, Release No. 34-63576
03/15/11 NASAA comment letter to FINRA regarding markups, commissions and fees, FINRA Regulatory Notice 11-08
03/15/11 NASAA comment letter to the Department of Labor regarding proposed rule: modernization of the definition of a fiduciary under ERISA, Release No. RIN 1210-AB32
03/10/11 NASAA comment letter to SEC regarding Net Worth Standard for Accredited Investors, Release Nos. 33-9177; IA-3144; IC-29572; File No. S7-04-11
02/10/11 NASAA Comments in Response to Release No. IA-3110 (File No.S7-36-10) and Release No.IA-3111 (File No.S7-37-10)
11/22/10 NASAA Comment Letter to SEC Regarding SEC Study on Enhancing Investment Adviser Examinations under Section 914 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010
11/04/10 NASAA Comment Letter to SEC Regarding Accredited Investor Standard, Title IV Provisions of the Dodd-Frank Wall Street Reform and Consumer Protection Act, File No. DF Title IV – Accredited Investor
11/04/10 NASAA Comment Letter to SEC Regarding Adding Disqualification Requirements to Regulation D Offerings, Title IX Provisions of the Dodd-Frank Wall Street Reform and Consumer Protection Act, File No. DF Title IX – Regulation D Disqualification
09/09/10 NASAA Comments on Release No. 34-62718; File No. SR-FINRA-2010-039
08/30/10 NASAA Comment Letter to the SEC Regarding Obligations of Brokers, Dealers and Investment Advisers
08/25/10 NASAA Comment Letter to SEC regarding FINRA proposal to amend the Discovery Guide used in FINRA arbitrations
08/23/10 NASAA Comment Letter to the SEC Regarding Target Date Retirement Fund Names and Marketing
07/30/10 Registration and Qualification Requirements for Certain Operations Personnel
07/13/10 NASAA Letter to SEC Regarding Application for Investment Adviser Registration, Part 2 (Form ADV, Part 2)
03/04/10 NASAA Comment Letter to the SEC Regarding Comments to Securities Exchange Act Release No. 60999 File No. SR-FINRA-2009-077
03/01/10 NASAA Comment Letter to FINRA Regarding Regulatory Notice 09-70 – Regstration and Qualification Requirements
02/16/10 NASAA Comment Letter to the SEC Regarding Amendments to Dark Pools; Release No. 34-60997; File No. S7-27-09
02/16/10 NASAA Comment Letter to FINRA Regarding Proposed Amendments Governing Payments to Unregistered Persons; Regulatory Notice 09-69
02/16/10 NASAA Comment Letter to the SEC Regarding Amendments to Credit Rating Agencies Release No. 34-61051; File No. S7-28-09; Release No. 33-9070; File No. S7-24-09
09/08/09 NASAA Comment Letter to the SEC Regarding Proposed Amendment to FINRA Rule 8312 Expanding the Scope of FINRA’s Public Disclosure System, BrokerCheck
08/21/09 NASAA Comment Letter on Proposed Rule Change Petition Submitted by the Public Investors Arbitration Bar Association (PIABA)
08/14/09 NASAA comment letter regarding the Financial Industry Regulatory Authority’s (FINRA) proposed rule consolidation for NASD Rule 2310 and NYSE 405
08/14/09 NASAA comment on Release No. IA-2876, File No. S7-09-09, “Custody of Funds or Securities of Clients by Investment Advisers
09/12/08 NASAA Comment Letter Regarding Regulation S-P: Privacy of Consumer Financial Information and Safeguarding Personal Information, File No. S7-06-08
09/10/08 NASAA Comments on the SEC’s Proposed Rule That Would Subject Certain Equity-Indexed Annuities to Regulation Under the Federal Securities Laws
05/16/08 NASAA Comment Letter on Proposed Rule and Form Amendments to Part 2 of Form ADV
04/24/08

NASAA Comment on FINRA Proposed Rule Change Relating to Amendments to the Codes of Arbitration Procedure To Establish New Procedures for Arbitrators To Follow When Considering Requests for Expungement Relief
04/17/08 NASAA Comment Letter to the SEC Release No. 34-57525; File No. SR-FINRA-2008-005 Notice of Filing of Proposed Rule Change Relating to Amendments to the Codes of Arbitration Procedure to Permit Submissions to Arbitrators After a Case has Closed Under Limited Circumstances
11/30/07 NASAA Comment Letter Regarding Treasury Department Review of the Regulatory Structure Associated with Financial Institutions
10/26/07 NASAA Comment Letter Regarding Revisions of Limited Offering Exemptions in Regulation D, Release No. 33-9928, IC-27922; File No. S7-18-07
09/24/07 NASAA Comment Revisions to Rule 144 and Rule 145 to Shorten Holding Period for Affiliates and Non-Affiliates For Resales of Restricted Securities
09/17/07 NASAA Comment Letter on Smaller Reporting Company Relief and Simplification File No. S7-15-07
09/12/07 NASAA Comment Letter to the SEC regarding proposed revisions to Form D and the implementation of an electronic filing system for Form D as discussed in Release Nos. 33-8814 and 34-2466
06/18/07 NASAA Letter to SEC Regarding SEC Roundtable Discussion Regarding Mutual Recognition
04/24/07 Joint Letter to SEC Chairman Cox from NASAA, Consumer Federation of America, Fund Democracy, the Financial Planning Association, the Investment Adviser Association, and the National Association of Personal Financial Advisers
04/13/07 NASAA Comment Letter to SEC Regarding File No. S7-22-06, Proposed Regulation R
04/09/07 NASAA Comment Letter Regarding NASD’s Notice to Members 07-12
04/02/07 NASAA Comment Letter to SEC Regarding File No. S7-25-06 Prohibition of Fraud by Advisers to Certain Pooled Investment Vehicles; Accredited Investors in Certain Private Investment Vehicles; Securities Act Release No. 33-8766; Investment Advisers Act Release No. 2576, 72 FR 400 (Jan. 4, 2007)
12/21/06 NASAA Comment on SEC Proposal Regarding Covered Securities Pursuant to Section 18 of the Securities Act of 1933, Securities Act Release No. 8754, 71 FR 67762
12/21/06 NASAA Supplemental Comments on SEC Proposal Regarding Covered Securities Pursuant to Section 18 of the Securities Act of 1933, Securities Act Release No. 8754, 71 FR 67762
10/04/06 NASAA Comments on Amendments to Regulation SHO
07/20/06 NASAA Comments on File No. SR-NASD-2003-168; Notice of Filing of Amendment Nos. 4 and 5 of the Proposed Rule Change Relating to the Release of Information Through NASD BrokerCheck
05/22/06 NASAA Comment Letter to MSRB Regarding “Customer Protection Obligations Relating to the Marketing of 529 College Savings Plans” Proposed Intrepretive Guidance
03/29/06 NASAA Comment Letter on NASDAQ Petition to Amend Rule 146(b) to Designate Securities Listed on the NASDAQ Capital Market as Covered Securities for the Purpose of Section 18 of the Securities Act of 1933 Rulemaking Petition File No. 4-5 13
09/19/05 NASAA Comment on Proposed Rule Governing Purchase, Sale, or Exchange of Deferred Variable Annuities
09/13/05 NASAA Comment on NASD Proposed Rule Change to Require Written Explanations in Arbitration Awards Upon the Request of Customers or Associated Persons
07/12/05 NASAA Comment on Proposed Uniform Branch Office Registration Form (Form BR); Release No. 34-51742; File No. SR-NASD-2005-30
11/15/04 NASAA Comment to the FTC Regarding the Franchise Rule Staff Report on the FTC`s Trade Regulation Rule on Disclosure Requirements and Prohibitions Concerning Franchising
10/18/04 NASAA Comment on SEC Proposal to Require Registration of Hedge Fund Advisers
10/06/04 Further NASAA Comment to the SEC Regarding its Proposed Rule on When Certain Broker-Dealers are Deemed Not to be Investment Advisers
09/08/04 NASAA Comment to the SEC Regarding Proposed Regulation B
08/24/04 NASAA Comment to the NASD Regarding Proposed Rule Governing the Purchase, Sale, or Exchange of Deferred Variable Annuities
06/22/04 NASAA Comment to the SEC Regarding the Use of Forms S-8 and 8-K by Shell Companies
05/21/04 NASAA Comment to the SEC Regarding Disclosures of Portfolio Managers of Registered Management Investment Companies
05/10/04 NASAA Comment Letter to SEC Regarding Redemption Fees
05/10/04 NASAA Comment Letter to SEC Regarding Mutual Fund 12b-1 Fees
04/23/04 NASAA Comment Regarding the SEC`s Proposal to Require Mutual Funds to Disclose Their Reasons for Selecting Investment Advisers
03/29/04 NASAA Comment to the SEC Regarding Simplification and Clarification of Consumer Privacy Notices Mandated by GLBA
03/21/04 NASAA Comment Regarding the SEC`s Proposed Rules to Facilitate Shareholder Nominations to Corporate Boards
03/15/04 NASAA Comment Regarding the SEC`s Proposal to Require Investment Advisers to Adopt a Written Code of Ethics
03/12/04 NASAA Comment Letter Regarding Proposed Amendments to NASD Rules 2710 (Corporate Financing) and 2810 (Direct Participation Programs)
03/10/04 NASAA Comment Letter Regarding Proposed SEC Rule to Change the Composition of Mutual Fund Boards of Directors
03/05/04 NASAA Comment Regarding the SEC`s Concept Release on Measures to Improve Disclosure of Mutual Fund Transaction Costs
02/27/04 NASAA Comment Letter Regarding Proposed SEC Mutual Fund Breakpoint Disclosure Rule
02/13/04 NASAA Comment Letter Regarding SEC File No. SR-NASD-2004-05, Proposed Amendment to NASD Rule 2370, Agents Borrowing or Lending Money from Customers
02/09/04 Comment letter to the Department of Labor regarding ERISA Investment Manager use of IARD
02/05/04 NASAA Supplemental Comment Letter Regarding SEC Proposed Rule on Compliance Programs of Investment Companies and Investment Advisers, File No. S7-03-03, Release Nos. IC-26299, IA-2204
01/26/04 NASAA Comment Letter Regarding NASD Proposed Rule Governing Allocations and Distributions of Shares in IPOs
01/09/04 NASAA Comment Letter Regarding NASD Notice To Members 03-76, Enhanced Access to BrokerCheck
01/06/04 Proposed New Definition of “Branch Office” Under NASD Rule 3010(g)(2), 1/7/2004
01/05/04 NASAA Comment Letter Regarding SEC Release No. 34-48709, Short Sales: Proposed Rule
12/18/03 NASAA Comment Letter Regarding SEC File No. SR-NYSE-2002-33, NYSE Proposed Amendments to Listed Company Manual on Corporate Governance
12/04/03 NASAA Supplemental Comment to the SEC Regarding Hedge Fund Solicitation and Advertising
10/30/03 NASAA comments on the proposed changes to AIMR’s Code of Ethics and Standards of Professional Responsibility
10/03/03 NASAA Comment Letter Regarding SEC File No. SR-NASD-98-74, NASD Proposal to Amend Rule 3110(f), Governing Use of Predispute Arbitration Agreements with Customers
07/23/03 NASAA Comment Letter Regarding SEC File No. SR-NASD-2003-92, NASD Proposed Rule 2370, Borrowing or Lending from Customers
07/08/03 NASAA Comment Letter Regarding SEC File No. 4-476, Request for Comment on Hedge Funds
06/04/03 NASAA Comment Letter Regarding SEC Proposed Rule 2130 Concerning the Expungement of Customer Dispute Information from CRD
04/18/03 NASAA Comment Letter Regarding SEC Proposed Rule on Compliance Programs of Investment Companies and Investment Advisers, File No. S7-03-03, Release Nos. IC-25925, IA-2107
04/08/03 NASAA Comment Letter to the OCC Regarding Docket No. 03-02. Proposed Rulemaking, 12 CFR 7.4000, Visitorial Powers
03/10/03 NASAA Comments on SRO Proposed Amendments to Rules Concerning Analyst Conflicts of Interest
02/18/03 Letter to the SEC Supporting NASD and NYSE Proposals to Expressly Allow State-Registered Investment Advisers to Receive and Vote Proxies on Behalf of Their Clients
01/06/03 NASAA Comment Letter Regarding NASD Notice to Members 02-74, Public Information Review
12/12/02 NASAA Comment Letter Regarding SEC Release No: 34-46745: “Proposed Rule: Definition of Terms in and Specific Exemptions for Banks, Savings Associations, and Savings Banks Under Sections 3(a)(4) and 3(a)(5) of the Securities Exchange Act of 1934″
09/23/02 NASAA Comment Letter Regarding NASD Notice to Members 02-55, Regulation of IPO Allocations and Distributions
09/23/02 NASAA Comment Letter Regarding Release Nos. 33-8119; 34-46301, Proposed Rule for Regulation Analyst Certification
08/21/02 NASAA Supplemental Comment Regarding Proposed Amendments To Investment Company Advertising Rules, File No. S7-17-02
04/18/02 NASAA Comment Letter Regarding SEC Release No. 34-45526, Research Analyst Conflicts of Interest
03/04/02 NASAA Comment Letter Regarding SEC Release No. 33-8041, Definition of Qualified Purchaser
01/08/02 NASAA Comment Letter Regarding Proposed Amendments to the FTC Trade Regulation Rule, “Disclosure Requirements and Prohibitions Concerning Franchising and Business Opportunity Ventures”
12/31/01 NASAA Comment Letter on Proposed Rules And Policies Relating To Expungement Of Information From The Central Registration Depository
11/23/01 NASAA Comment Letter on Proposed Changes to the CFP Board`s Code of Ethics and Professional Responsibility
08/15/01 NASAA Comment Letter on NASD Notice to Members 01-45
07/16/01 NASAA Comment Letter on the SEC Interim Final Rules for the Definition of Terms in and Specific Exemptions for Banks, Savings Associations, and Savings Banks under Sections 3(a)(4) and 3(a)(5) of the Securities Exchange Act of 1934
04/01/01 NASAA Comment Letter to the CFTC Regarding Proposed Rule, “A New Regulatory Framework for Trading Facilities, Intermediaries and Clearing Organizations”
02/12/01 NASAA Comment Letter on NASD Notice to Members 0106 – Member Facilitations of Lending between Customers
10/10/00 NASAA Comment Letter to the Federal Trade Commission Regarding Gramm-Leach-Bliley Act Privacy Safeguards Rule, 16 CFR Part 313-Comment
06/30/00 NASAA Comment Letter on the Proposed Rule and Form Amendments under the Securities Act of 1933 and the Investment Company Act of 1940 to Improve Disclosure to Investors of the Effect of Taxes on the Performance of Mutual Fund Companies
05/30/00 Telemarketing Sales Rule Comment Letter to the Federal Trade Commission
05/12/00 NASAA Comment Letter on Issues Relating to Market Fragmentation, SEC Release No.34-42450; File No. SR-NYSE-99-48
04/28/00 NASAA Comment Letter on Selective Disclosure and Insider Trading; SEC Release No. IC-24209; File No. S7-31-99
03/31/00 NASAA Comment Letter on SEC Regulation S-P: Privacy of Consumer Financial Information, Release Nos. 34-42484,IC-24326, IA-1856; File No. S7-6-00
03/31/00 NASAA Comment Letter to the FTC on Gramm-Leach-Bliley Act Privacy Rule, 16 CFR Part 313
03/10/00 NASAA Comment Letter on Recent Proposed Amendments to NASD Rules 2360 and 2361 Relating to the Opening of Day Trading Accounts
01/31/00 NASAA Comment Letter on the SEC Proposed Rule Change Regarding Unlisted Trading Privileges in Regard to Initial Public Offerings
01/28/00 NASAA Comment Letter on the SEC Proposed Rule Regarding the Role of Independent Directors of Investment Companies
01/14/00 NASAA Comment Letter on the SEC Proposed Rule: Certain Broker-Dealers Deemed Not To Be Investment Advisers
01/06/00 NASAA Comment Letter on President Clinton’s Consumer Fraud Initiatives Directives
12/27/99 NASAA Comment Letter on the SEC Concept Release Regarding the Regulation of Short Sales of Securities
05/28/99 NASAA Day Trading Project Group Comment Letter on NASDR Proposed Rules Regarding Approval Procedures for Day Trading Accounts
12/09/98 Re-Proposed Books and Records Requirements as Amendments to Rules 17a-3 and 17a-4 of the Securities Exchange Act of 1934
01/29/97 Public Availability of Information about Consumers Letter to Federal Reserve
12/12/96 Books and Records Comment Letter to SEC
All Comment Letters, Regulatory Activity, Regulatory Comment Letters