SEC Rule Announcement

[Robert Hettinga]

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From: jmuller at brobeck.com
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Date: Thu, 5 Feb 1998 14:39:08 -0800
Subject: Re[2]: SEC Rule Announcement
To: "Robert Hettinga" <rah at shipwright.com>, <dcsb at ai.mit.edu>,
        "Arnold G. Reinhold" <reinhold at world.std.com>
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Reply-To: jmuller at brobeck.com

     This is actually an NASD rule change; the SEC reviews proposed NASD
     rule changes and almost always approves them.  The NASD rule change is
     in Notice to Members 98-11 (available at
     http://www.nasdr.com/2610.htm), and was approved by the SEC on
     December 31, 1997, effective February 15.

     The NASD views the change as simply clarifying a requirement that was
     already in place:  the rule previously required that NASD member
     broker/dealers establish procedures for the review of all
     correspondence relating to solicitation or execution of securities
     transactions.  The rule as amended will state that these procedures
     must apply to all incoming and outgoing written and electronic
     correspondence with the public relating to the firm's investment
     banking or securities business.  The rule itself does not say anything
     about home offices, but in the introduction to the rule, the NASD says
     that it will "expect members to prohibit correspondence with customers
     from employees' home computers or through third party systems unless
     the firm is capable of monitoring such communications."

     My mama taught me if I can't say anything nice, I shouldn't say
     anything at all, so I will not comment on the rule.  If you're
     interested enough to go to the NASD Web site shown above, you will
     probably also want to look at Notice to Members 98-3, which sets out
     general principles for electronic delivery of information between
     brokers and their customers.


     John Muller
     mailto:jmuller at brobeck.com

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-----------------
Robert Hettinga (rah at shipwright.com), Philodox
e$, 44 Farquhar Street, Boston, MA 02131 USA
"... however it may deserve respect for its usefulness and antiquity,
[predicting the end of the world] has not been found agreeable to
experience." -- Edward Gibbon, 'Decline and Fall of the Roman Empire'
The e$ Home Page: http://www.shipwright.com/
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