Issue
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Action
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Status
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2006
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NASAA proposed amendments to guidelines for DPP suitability
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FSI comment letter submitted November 27, 2006
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Pending action by NASAA
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Massachusetts proposed ban on use of certain professional designations
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FSI comment letter submitted on November 8, 2006
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Pending action by MA
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NASD NtM 06-31 - Request for comment on regulatory relief to be granted due to possible pandemic or other major business disruption
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FSI comment letter submitted on September 15, 2006
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Pending action by NASD.
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NASD proposed amendment to IM-2210-4 - Member firms who refer on their Internet Web site to the firm's membership in NASD to provide hyperlink to NASD's Web site
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FSI comment letter submitted on July 27, 2006.
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Proposal amended in response to FSI comments. Effective July 17, 2007. See NASD NtM 07-02.
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NASD proposed amendment to IM-2210-4 - Would require member firms who refer on their Internet Web site to the firm’s membership in the NASD to provide a hyperlink to the NASD’s Web site
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FSI comment letter submitted on July 27, 2006
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Pending Action by NASD
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NASD Proposed Rule 2821 - Members' Responsibilities Regarding Deferred Variable Annuities
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FSI comment letter submitted on July 19, 2006. See also FSI prior comment letter submitted on September 19, 2005. |
NASD filed third amended proposal wiht SEC on November 15, 2006. Pending action by SEC. |
MSRB proposed interpretive guidance concerning customer protection obligations of broker-dealers in the marketing of 529 plans
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FSI comment letter submitted May 23, 2006 |
Proposal amended in response to FSI comments. Effective August 7, 2006.
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NASD proposed amendments to Rule 2211 - pre-use principal approval of certain client correspondence
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FSI comment letter submitted on March 21, 2006
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SEC approved amendments. Effective December 1, 2006.
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NASD Notice to Members 06-06 (January 23, 2006) - Proposed interpretive guidance on gifts and business entertainment
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FSI comment letter submitted on February 23, 2006
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Pending action by NASD. Amended proposal expected.
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2005
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NASD Proposed Rule 2821 - Variable Annuities Suitability and Disclosure
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FSI comment letter submitted on September 19, 2005
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Pending action by SEC
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SEC Rule 202(a)(11)-1 (Broker-Dealer exemption from Investment Advisers Act)
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FSI letter requesting extension of compliance date submitted on August 25, 2005
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On September 13, 2005, SEC extended compliance deadline until January 31, 2006
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NASD Notice to Members 05-40 - Sales Contests & Non-Cash Compensation
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FSI comment letter submitted on August 5, 2005
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Pending action by NASD
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NASD Notice to Members 05-27 - Pre-approval of Correspondence including e-mail
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FSI comment letter submitted May 27, 2005
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Pending action by NASD
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NASD Notice to Members 05-25 - Pre-approval of Advertising
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FSI comment letter submitted May 20, 2005
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Pending action by NASD
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IRS Proposed Revenue Ruling 90-24 - Revised regulations concerning Section 403(b) tax-sheltered annuity contracts
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FSI comment letter submitted April 21, 2005 |
Pending action by IRS |
SEC Point of Sale & Confirmation Disclosures
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FSI comment letter submitted April 4, 2005
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Pending action by SEC
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SEC SRO Governance Rules/Concept Release on Future of Self-Regulation
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FSI comment letter on SRO Rules proposal submitted on March 8, 2005
FSI comment letter on Concept Release submitted on March 8, 2005
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Pending action by SEC
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2004
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NASD pronouncement re: Block transfers/use of negative consent letters
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Discussion with Mary Schapiro at Public Policy Day on October 13, 2004
FSI Comment letter submitted on November 15, 2004
Further discussion with NASD staff by members of NASD Independent Dealers/Insurance Affiliates Committee
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NASD clarified position that negative consent letters can be used if transferring firm issues them
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SEC proposal re: Broker-Dealer Exemption from Investment Advisers Act
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FSI Comment letter submitted September 22, 2004
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SEC issued revised rule for further comment
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NASD proposal re: CEO/CCO Certification
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FSI Comment letter submitted August 24, 2004
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Proposal modified to include only CEO certification
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SEC proposal re: Regulation B (broker-dealers offering brokerage services to bank customers)
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Member Briefing distributed to all FSI members July 30, 2004
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Rule adopted
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NASD proposal re: Variable Annuity Suitability & Disclosure
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FSI Comment letter submitted July 23, 2004
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Proposal significantly modified (e.g., point of sale disclosure and short turnaround on principal review), resubmitted to SEC for further comment
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SEC request for comments re: 12b-1 fees
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FSI Comment letter submitted May 10, 2004
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No action yet by SEC
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SEC proposal re: Mandatory Redemption Fees
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FSI Comment letter submitted May 10, 2004 |
No action yet by SEC |
| Mutual Fund Reform Legislation |
Member Briefing & Talking Points for broker-dealers and reps distributed April 15, 2004
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No action by Congress on 12b-1 fees ban |
SEC proposal re: Mutual Fund Point of Sale/Confirmation Disclosures
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FSI Comment letter submitted April 12, 2004
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SEC's revised proposal released for comment on March 3, 2005
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NASD Breakpoints Project
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Letter with questions submitted December 1, 2003
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Some of our questions were included in NASD’s FAQ |