Division of Trading and Markets No-Action, Exemptive, and Interpretive Letters
This page contains Division of Trading and Markets (the "Division") no-action letters, interpretive letters, and exemptive letters/orders dated on or after January 1, 2002. Letters issued before that date may be obtained by submitting a request for a paper copy. Selected letters issued before January 1, 2002 may appear in other places on this website or may be found on the Georgetown University Library’s webpage.
The U.S. government, including the U.S. Securities and Exchange Commission, neither endorses nor guarantees in any way the external organizations, services, advice, or products included in these website links. Furthermore, the U.S. government neither controls nor guarantees the accuracy, relevance, timeliness, or completeness of the information contained in non-government website links.
Process for Requesting No-Action, Interpretive and Exemptive Letters from the Division: The Division welcomes written requests for no-action, interpretive and exemptive letters relating to the areas of the federal securities laws, rules and regulations that the Division administers and interprets.
- Request letters may be sent to the following email address: tradingandmarkets@sec.gov
- For assistance in preparing a request for a no-action, interpretive or exemptive letter, please refer to the General Information section below. You may call 202-551-5777 or send an email to tradingandmarkets@sec.gov with any questions about preparing a request letter.
- Please read our Privacy Act Notice to learn about how we may use the information you send to us.
General Information About No-Action,
Interpretive and Exemptive Request Letters
- Procedures for submitting request letters. The Commission has specified certain procedures to be followed by persons submitting requests for no-action or interpretive letters. Request letters should include the following information:
- the specific subsection of the particular statute to which the letter pertains.
- the names of the company or companies and all other persons involved. Letters relating to unnamed companies or persons, or to hypothetical situations, will not be answered.
- all of the facts necessary to reach a conclusion in the matter, but they should also be concise and to the point.
- be limited to the particular situation involving the problem at hand, and should not attempt to include every possible type of situation which may arise in the future.
- indicate why the writer thinks a problem exists, his or her own opinion in the matter and the basis for such opinion.
- if the writer is seeking confidential treatment, the request for confidential treatment and the reason it is being requested (including the legal basis) should be included in a separate letter that is submitted with the no-action request letter.
See, e.g., Procedure Applicable to Requests for No-Action or Interpretative Letters, Release Nos. 33-5127, 34-9065, 35-16972, 39-289, IC-6330, IAA-2811, (Jan. 25, 1971) 36 FR 2600 (Feb. 9, 1971).
- Conduct research and provide results with your requests. Requests benefit from an analysis of relevant law. Accordingly, we encourage you first to research all available authority before submitting a request, and include the results of your research in your request.
For assistance conducting research on this website, see Researching the Federal Securities Laws through the SEC Website. Also note that some resources for conducting research are available through the Division of Trading and Markets webpage, including, but not limited to, reviewing prior Division no-action, interpretive and exemptive letters (links to which can be found below).
Investor Complaints: If you wish to file an investor complaint, please use our online Investor Complaint Form. Please read the Investor Bulletin: Investor Complaints for information on what we will do with your complaint and other options for resolving your complaint.
- Subject Categories for No-Action Letters
- Subject Category List of No-Action Letters
- Selected Class Letters
- Alphabetical List of No-Action Letters
- Chronological List of No-Action Letters
- Subject Category List of Interpretive Letters
- Chronological List of Exemptive Orders
Subject Categories for No-Action Letters
- Associated Persons of Broker-Dealers (including Registration, Bars, Statutory Disqualification, and Rule 19h-1)
- "Bank" – Definition
- Broker-Dealer Books and Records and Reporting Requirements
- Broker-Dealer Customer Protection Rule - Rule 15c3-3
- Broker-Dealer Net Capital Requirements - Rule 15c3-1
- Broker-Dealer Registration (including Form BD Interpretations, Withdrawal from Broker-Dealer Registration and Successors)
- Broker-Dealer Registration – Clerical and Ministerial Activities
- Broker-Dealer Registration – Dealers
- Broker-Dealer Registration – Exemptions from Registration
- Broker-Dealer Registration – Finders
- Broker-Dealer Registration – Foreign Broker-Dealers (including International Activities of U.S. Broker-Dealers and Rule 15a-6)
- Broker-Dealer Registration – Limited Broker-Dealer Functions
- Broker-Dealer Registration – Networking (Depository Institutions and Insurance Companies)
- Broker-Dealer Registration – Other
- Clearing Agencies
- Confirmations – Rule 10b-10
- Disclosure of Order Execution Information – Rule 605 (formerly Rule 11Ac1-5)
- Disclosure of Order Routing Information – Rule 606 (formerly Rule 11Ac1-6)
- Dissemination of Quotations – Rule 602 (formerly Rule 11Ac1-1)
- ECNs ("Electronic Communications Networks")
- Exchange Member Trading – Section 11(a)
- Extension of Credit on New Issues – Section 11(d)
- Foreign Market Communications with QIBs
- Keep and Preserve Paper Copies – Rule 17a-1
- Multiple Section Relief (e.g. exchange traded funds and other basket products)
- Municipal Auction Rate Securities
- Municipal Securities Brokers and Dealers
- Municipal Securities Disclosure – Rule 15c2-12
- National Market System Rules, Miscellaneous – Section 11A
- National Market System Plans
- Other
- Penny Stock Rules
- Regulation Best Interest and Form CRS
- Regulation E
- Regulation S-P
- Regulation SHO
- Regulation T
- Risk Assessment Rules – Rules 17h-1T and 17h-2T
- Rule 10a-1, Short Sales
- Rule 10b-18, Issuer Repurchases
- Rule 12d2-2, Removal from Listing and Registration
- Rule 14e-5, Purchases Outside a Tender Offer
- Rule 15c2-4, Transmission or Maintenance of Payments Received in Connection with Underwritings
- Rule 15c2-11, Initiation of Quotations
- Rule 17Ad-17, Lost Securityholders and Unresponsive Payees
- Rule 101 of Regulation M, Activities By Distribution Participants
- Rule 102 of Regulation M, Activities By Issuers and Selling Security Holders During a Distribution
- Section 31 Fees
- Security-based Swap Dealers
- Security Futures Products Brokers and Dealers
- Shad-Johnson Letters
- Transfer Agents
- Vendor Display Rule Interpretive Guidance
List of No-Action Letters by Subject Category
Associated Persons of Broker-Dealers (including Registration, Bars, Statutory Disqualification, and Rule 19h-1)
- Jeffrey A. Wolfson, July 26, 2012
- Robert A. Wolfson, July 26, 2012
- Financial Industry Regulatory Authority, Inc., March 17, 2009
- Securities Industry and Financial Markets Association, November 20, 2008
- NASD, July 27, 2007
- NYSE Regulation, Inc., August 1, 2006
- New York Stock Exchange, Inc., February 11, 2005
- Maine Securities Regulator, April 9, 2002
Broker-Dealer Books and Records and Reporting Requirements
- Securities Industry and Financial Markets Association, December 5, 2024
- Securities Industry and Financial Markets Association, December 9, 2022
- Securities Industry and Financial Markets Association, December 9, 2020
- Securities Industry and Financial Markets Association, December 12, 2018
- Financial Industry Regulatory Authority, October 29, 2018
- Financial Industry Regulatory Authority, April 12, 2018
- Lincoln Financial Distributors, Inc., February 17, 2017
- Financial Industry Regulatory Authority, January 27, 2017
- Securities Industry and Financial Markets Association, December 12, 2016
- Securities Industry and Financial Markets Association, January 9, 2015
- Securities Industry and Financial Markets Association, January 11, 2013
- Securities Industry and Financial Markets Association, January 11, 2011
- Securities Industry and Financial Markets Association, January 11, 2010
- Financial Industry Regulatory Authority, September 1, 2009
- Omgeo, March 19, 2009
- Securities Industry and Financial Markets Association, January 10, 2008
- Securities Industry and Financial Markets Association, December 29, 2006
- Securities Industry Association, July 31, 2006
- Securities Industry Association, July 11, 2006
- New York Stock Exchange, Inc. and NASD Regulation, Inc., December 16, 2005
- Securities Industry Association, February 10, 2005
- Securities Industry Association, February 12, 2004
Broker-Dealer Customer Protection Rule - Rule 15c3-3
- Financial Industry Regulatory Authority (Broker-Dealers Borrowing Fully Paid and Excess Margin Securities from Customers) October 22, 2020
- Financial Industry Regulatory Authority (ATS Role in the Settlement of Digital Asset Security Trades) September 25, 2020
- Charles Schwab & Co., Inc. August 13, 2020
- Securities Industry and Financial Markets Association, January 8, 2020
- BancWest Investment Services, Inc., March 21, 2019
- National Financial Services LLC, Re: Cash in a Customer Reserve Account under Rule 15c3-3(e)(5), March 8, 2018
- Financial Industry Regulatory Authority (Definition of "Fully Paid Securities" under Rule 15c3-3), September 28, 2017
- N.I.S. Financial Services, Inc., August 15, 2017
- National Securities Clearing Corporation, December 1, 2016
- MML Investors Services, LLC, July 19, 2016
- NYLIFE Securities LLC, March 12, 2015
- Securities Industry and Financial Markets Association, Re: Certain Amendments to Rule 15c3-3, February 5, 2015
- Financial Industry Regulatory Authority, Re: Broker-Dealers Holding Cash in a Reserve Account at a Non-Affiliated U.S. Branch of a Foreign Bank under Rule 15c3-3, February 26, 2014
- Securities Industry and Financial Markets Association, Re: Certain Amendments to Rule 15c3-3, February 26, 2014
- Securities Industry and Financial Markets Association, December 21, 2012
- Financial Industry Regulatory Authority, Inc., December 10, 2012
- Charles Schwab & Co., Inc., February 3, 2012
- Sanford C. Bernstein & Co., LLC, June 9, 2009
Broker-Dealer Net Capital Requirements – Rule 15c3-1
- Cboe Exchange, Inc., Re: Treatment of Certain Corporate Bond Index Futures under Appendix A to Rule 15c3-1, December 6, 2024
- 2000 Vadala (Marketability of Certain Securities) Letter Update, August 18, 2022
- Financial Industry Regulatory Authority (Net Capital Treatment of Certain U.S. Treasury Exchange-Traded Funds), June 2, 2022
- Securities Industry and Financial Markets Association, May 15, 2020; see also Incoming Letter
- Securities Industry and Financial Markets Association, Re: Treatment of Operating Leases under Rule 5c3-l, October 23, 2018
- Invesco PowerShares Capital Management LLC, Re: Net Capital Treatment of PowerShares Treasury Collateral Portfolio, March 6, 2018
- Securities Industry and Financial Markets Association, Re: Treatment of Revenue from Contracts with Customers under Rule 15c3-1, January 4, 2018
- Securities Industry and Financial Markets Association, November 8, 2016
- Financial Industry Regulatory Authority, Inc., Re: Treatment under Rule 15c3-l of Margin Posted by Broker-Dealers with Respect to Swaps, August 19, 2016
- Financial Industry Regulatory Authority, Inc., re: Definition of "Ready Market" with regard to Foreign Equity Securities pursuant to Rule 15c3-1(c)(11)(i), February 9, 2016
- Securities Industry and Financial Markets Association, December 21, 2012
- Financial Industry Regulatory Authority, Inc., December 10, 2012
- Chicago Board Options Exchange, Inc. and Financial Industry Regulatory Authority, Inc., May 4, 2012
- The Depository Trust & Clearing Corporation, March 13, 2009
- Japan Credit Rating Agency, Ltd., May 23, 2007
- NASD Regulation, Inc., re: Net Capital Relief Related to Certain Transactions in the Securities of Gluv Corp., June 16, 2005
- A.M. Best Company, Inc., March 3, 2005
- Recording Certain Broker-Dealer Expenses and Liabilities, July 11, 2003
- Dominion Bond Rating Service Limited, February 24, 2003
Broker-Dealer Registration (including Form BD Interpretations, Withdrawal from Broker-Dealer Registration and Successors)
- Barclays Capital Inc., September 19, 2008
- JPMorgan Chase & Co., March 19, 2008
- Woodstock Financial Group, Inc., January 14, 2008
- Woodstock Financial Group, Inc., November 7, 2007
- NASD, Inc., September 30, 2005
Broker-Dealer Registration –
Clerical and Ministerial Activities
- ADP TotalSource, Inc., December 4, 2007
- eEmployers Solutions, Inc., December 3, 2007
- TriNet Group, Inc., February 17, 2006
- Headway Corporate Staff Administration, August 14, 2002
Broker-Dealer Registration – Dealers
- Acqua Wellington North America Equities Fund, Ltd., July 11, 2001
Broker-Dealer Registration – Exemptions from Registration
Broker-Dealer Registration – Finders
- Brumberg, Mackey & Wall, P.L.C., May 17, 2010
- Hallmark Capital Corporation, June 11, 2007
- John W. Loofbourrow Associates, Inc., June 29, 2006
Broker-Dealer Registration – Foreign Broker-Dealers (including International Activities of U.S. Broker-Dealers and Rule 15a-6)
- Roland Berger Strategy Consultants, May 28, 2013
- Ernst & Young Global Ltd., July 12, 2012
- LiquidityHub Limited, November 28, 2007
- Dinosaur Securities, LLC, June 23, 2006
- Cleary, Gottlieb, Steen and Hamilton, March 24, 1997
- Bear, Stearns & Co. Inc.; CS First Boston corporation; CSFP Capital, Inc.; Goldman, Sachs & Co.; Lehman Brothers Inc.; Morgan Stanley & Co. Incorporated; and Salomon Brothers Inc, January 30, 1996
Broker-Dealer Registration –
Limited Broker-Dealer Functions
- M&A Brokers, March 29, 2023
- TMX Group, December 28, 2020; Incoming Letter
- Neptune Networks Ltd., March 4, 2020; Incoming Letter
- Catalyst Corporate Federal Credit Union, April 11, 2018
- Canadian Stock Transfer Company Inc., March 4, 2015
- Canadian Stock Transfer Company Inc., March 4, 2014
- Canadian Stock Transfer Company Inc., March 4, 2013
- S3 Matching Technologies LP, July 19, 2012
- The Investment Archive, LLC, May 14, 2010
- Putnam Investor Services, Inc., December 31, 2009
- Country Business, Inc., November 8, 2006
- EIG Mutual Holding Company, October 25, 2006
- Professional Project Services, Inc., June 22, 2006
- CommandTRADE, LP, December 28, 2005
- TEOCO Corporation, October 20, 2005
- R & H Management, L.L.C., April 25, 2005
- Texas Treasury Safekeeping Trust Company, June 16, 2004
- Investacorp Group, Inc., September 26, 2003
- Loffa Interactive Corp., Inc., September 12, 2003
- Scripophily.com, August 14, 2002
- Century Business Services, Inc. and CBIZ Financial Solutions, Inc., March 1, 2002
- OneShare.com, January 16, 2002
Broker-Dealer Registration – Networking
(Depository Institutions and Insurance Companies)
- Committee of Annuity Insurers, Securities Industry and Financial Markets Association, and American Council of Life Insurers, April 23, 2013
- M Financial Holdings, Inc., May 8, 2006
- Maine Securities Regulator, April 9, 2002
- Chubb Securities Corporation November 24, 1993
Broker-Dealer Registration – Other
- Social Finance Inc., November 13, 2014
- AngelList LLC, March 28, 2013
- FundersClub Inc. and FundersClub Management LLC, March 26, 2013
- Packerland Brokerage Services, March 18, 2013
- Roadshow Broadcast LLC, May 6, 2011
- Nemzoff & Company, LLC, November 30, 2010
- Capital Institutional Services, Inc., April 13, 2007
- Goldman, Sachs & Co., January 17, 2007
- Welton Street Investments, LLC, June 27, 2006
- Wolff Juall Investments, LLC, May 17, 2005
- Dilworth Capital Management, LLC, December 9, 2004
- Edward Mahaffy, March 6, 2003
- National Association of Securities Dealers Order Audit Trail Rules 6950 through 6957, July 25, 2002
- Swiss American Securities Inc. and Streetline, Inc., May 28, 2002
- Attkisson, Carter, & Akers, June 23, 1998
- 1st Global, Inc., May 7, 2001
- Charles Schwab & Co., Inc., November 27, 1996
- Options Clearing Corporation, November 18, 2019
- Paxos Trust Company, LLC (Time Limited No-Action), October 28, 2019
- Options Clearing Corporation, February 27, 2019
- SS&C Technologies, Inc., October 2, 2018
- Chicago Mercantile Exchange Inc., January 15, 2016
- LCH.Clearnet SA, December 30, 2013
- LCH.Clearnet SA, September 27, 2013
- Options Clearing Corporation, November 29, 2012
- Options Clearing Corporation, June 4, 2012
- MIAX PEARL, LLC, September 21, 2020
See also: Order Granting Exemption, Release No. 34-89942 - MEMX LLC, September 18, 2020
See also: Order Granting Exemption, Release No. 34-89926 - Long-Term Stock Exchange, Inc., September 9, 2020
See also: Order Granting Exemption, Release No. 34-89790 - Citigroup Global Markets Inc., August 28, 2019
- Financial Information Forum, September 5, 2018
- Investors' Exchange LLC, July 26, 2016; see also Order Granting Exemption, Release No. 34-78417
- Bloomberg L.P., November 24, 2015
- MarketAxess Corporation, January 26, 2015
- Nomura Securities International Inc., December 10, 2012
- BOX Options Exchange, May 11, 2012; see also Order Granting Exemption, Release No. 34-66976
- Omgeo LLC, November 19, 2010
- BATS Y-Exchange, October 12, 2010
- NASDAQ OMX PHLX, September 9, 2010
- EDGA Exchange, May 26, 2010
- EDGX Exchange, May 26, 2010
- Society for Worldwide Interbank Financial Telecommunication, May 27, 2010
- BATS Exchange, Inc., February 25, 2010
- BNY Mellon, December 31, 2009
- Legg Mason Investor Services, LLC, April 7, 2009
- Boston Stock Exchange, December 23, 2008
- BATS Exchange, Inc., October 23, 2008
- Pershing LLC, September 10, 2008
- SS&C Technologies, Inc., August 13, 2008
- Omgeo LLC, March 12, 2008
- Bloomberg Tradebook LLC and Calyon Inc., December 31, 2007
- Chicago Stock Exchange, Inc., November 15, 2007
- SunGard Institutional Brokerage, Inc., July 3, 2007
- UBS Financial Services Inc., May 24, 2007
- Fixed Income Clearing Corporation, May 23, 2007
- Wachovia Securities, April 30, 2007
- FSC Securities Corporation, January 30, 2007
- Omgeo, LLC, December 14, 2006
- International Securities Exchange, LLC, December 7, 2006
- TD Ameritrade, Inc., November 30, 2006
- Philadelphia Stock Exchange, Inc., November 9, 2006
- Boston Stock Exchange, November 8, 2006
- National Stock Exchange, October 13, 2006
- International Securities Exchange, Inc. , August 18, 2006
- Wachovia Securities, August 15, 2006
- J.P. Morgan Securities Inc., August 4, 2005
- D.A. Davidson & Co., June 10, 2005
- William Blair & Company L.L.C., June 10, 2005
- Morgan Keegan & Co., Inc., April 20, 2005
- Sanford C. Bernstein & Co., LLC, April 18, 2005
- Average Price, Multiple Capacity Confirmations, March 3, 2005
- Nasdaq Stock Market, Inc., January 26, 2005
- The Equitable Life Assurance Society of the United States, October 20, 2004
- The Pacific Exchange, Inc., April 30, 2004
- Nasdaq Stock Market, Inc., September 15, 2003
- Goldman, Sachs & Co., August 14, 2003
- Edward D. Jones & Co., LP, August 1, 2003
- Trade Web, Jul 22, 2003
Disclosure of Order Execution Information – Rule 605 (formerly Rule 11Ac1-5)
- SelectNet and SuperMontage, June 4, 2002
- Nasdaq Stock Market, Inc., September 21, 2001
- NASD Small Firms Advisory Board, June 22, 2001
- New York Stock Exchange, Inc., June 22, 2001
- Nasdaq Stock Market, Inc., June 22, 2001
- Market Systems, Inc., June 22, 2001
- Securities Industry Association, April 12, 2001
- Securities Industry Association, March 12, 2001
- Nasdaq Stock Market, Inc., March 12, 2001
Disclosure of Order Routing Information – Rule 606 (formerly Rule 11Ac1-6)
- Securities Industry Association, September 21, 2001
- NASD Small Firm Advisory Board, September 21, 2001
- First Union Securities, Inc., June 22, 2001
Dissemination of Quotations – Rule 602 (formerly Rule 11Ac1-1)
- NASDAQ OMX BX, Inc., November 28, 2014
- NYSE Arca, Inc., March 25, 2014
- The NASDAQ Stock Market LLC, February 15, 2013
- BATS Y-Exchange, Inc., November 27, 2012
- New York Stock Exchange LLC and NYSE Amex LLC, July 3, 2012
- National Association of Securities Dealers, Inc., July 28, 2006
- Chicago Board Options Exchange, Inc., July 12, 2004
- International Securities Exchange, Inc., June 24, 2004
ECNs ("Electronic Communications Networks")
- Bloomberg Tradebook LLC, June 28, 2006
- BATS Trading, Inc., June 28, 2006
- OnTrade, Inc., June 28, 2006
- Direct Edge ECN, June 28, 2006
- Track ECN, June 28, 2006
- BATS Trading, Inc., May 8, 2006
- Direct Edge ECN LLC, March 3, 2006
- BATS Trading, Inc., February 17, 2006
- OnTrade, Inc./NexTrade ECN: Withdrawal of No-Action Position, January 11, 2006
- OnTrade, Inc., January 11, 2006
- Track ECN, October 21, 2005
- Bloomberg Tradebook LLC, November 17, 2005
- Inet ATS, Inc., October 21, 2005
- Direct Edge ECN LLC Purchase of ATTAIN ECN, October 21, 2005
- Domestic Securities, Inc./ATTAIN ECN, October 21, 2005
- Attain System, October 7, 2005
- OnTrade, Inc., October 7, 2005
- BRUT System, January 6, 2005
- Trading System Operated by OnTrade, Inc., January 6, 2005
- Inet ECN, January 6, 2005
- Tradebook System, January 6, 2005
- Attain System, January 6, 2005
- Track System, January 6, 2005
- OnTrade, Inc., April 2, 2004
- Inet ECN, April 2, 2004
- Track ECN, April 1, 2004
- NexTrade, Inc., April 1, 2004
- BRUT System, April 1, 2004
- Attain Systems, April 1, 2004
- Bloomberg Tradebook, April 1, 2004
- The Island ECN, November 7, 2002
- Instinet Corporation, November 1, 2002
- GlobeNet Trading System, March 29, 2002
- Instinet Real-Time Trading Services, March 29, 2002
- Island System ECN, March 29, 2002
- MarketXT, March 29, 2002
- REDI System, March 29, 2002
- Track ECN, March 29, 2002
- BRUT ECN, LLC, February 1, 2002
Exchange Member Trading – Section 11(a)
- The Operating Committee of the Options Linkage Authority, May 30, 2003
- Chicago Board Options Exchange, March 31, 2003
- Large Order Utility System, March 12, 2003
- American Stock Exchange, July 9, 2002
- RAES System, May 16, 2002
- AUTOM System, April 15, 2002
Extension of Credit on New Issues – Section 11(d)
- NYSE Arca, Inc., September 3, 2013
- Charles Schwab, Inc., August 23, 2012
- Telstra Corporation Limited, October 5, 2006
- Doughty Hanson & Co Investments L.P. Incorporated, September 12, 2006
- Securities Industry Association, June 8, 2006
- streetTRACKS Gold Trust®, December 12, 2005
- iShares COMEX Gold Trust, December 12, 2005
- WEBS Index Series, November 22, 2005
- streetTRACKS Series Trust, November 22, 2005
- Select Sector SPDRs, November 22, 2005
- iShares, Inc. MSCI Index Funds, November 22, 2005
- Fresco Index Shares Funds, November 22, 2005
- Foreign Fund, Inc., November 22, 2005
- Securities Industry Association, November 21, 2005
- Spark Infrastructure Group, November 8, 2005
- Macquarie Media Holdings Limited and Macquarie Media Trust, September 27, 2005
- Popular High Grade Fixed-Income Fund, Inc., March 31, 2004
- Popular Total Return Fund, Inc., July 1, 2003
Foreign Market Communications with QIBs
- Representation Letter from B3, April 12, 2024
- Representation Letter from NSE IFSC, April 4, 2024
- Representation Letter from Cboe Europe, May 23, 2023
- Nasdaq Stockholm, September 19, 2022
- Representation Letter from Cboe Europe, September 1, 2021
- Representation Letter from National Stock Exchange of India, December 21, 2020
- Representation Letter from Cboe Europe, November 13, 2020
- Representation Letter from Nasdaq Stockholm, January 15, 2020
- Letter from LSE Derivatives, June 3, 2019
- Representation Letter from Korea Exchange, September 18, 2018
- Representation Letter from Taiwan Futures Exchange, February 2, 2016
- Representation Letter from Eurex Deutschland, December 1, 2015
- Representation Letter from Borsa Italiana, September 4, 2015
- Representation Letter from HKFE, August 24, 2015
- Representation Letter from SEHK, August 24, 2015
- Representation Letter from LSE Derivatives, November 12, 2014
- Representation Letter from Euronext Amsterdam, September 17, 2014
- Representation Letter from Euronext Brussels, September 17, 2014
- Representation Letter from Euronext Paris, September 17, 2014
- Representation Letter from ICE Futures Europe, March 28, 2014
- Representation Letter from Tokyo Stock Exchange and Osaka Securities Exchange, March 14, 2014
- LIFFE A&M and Class Relief, July 1, 2013
- LIFFE Administration and Management, July 29, 2009
- ASX Limted, August 13, 2007
- Tokyo Stock Exchange, Inc., November 20, 2006
- Eurex, May 3, 2006
- Eurex, July 27, 2005
- Borsa Italiana S.p.A., September 24, 2004
- EDX London Limited and OM London Exchange Limited, October 29, 2003
- Tokyo Stock Exchange, Inc., November 15, 2002
- ParisBourse SA, December 6, 1999
- Tokyo Stock Exchange, July 27, 1999
- Osaka Securities Exchange, July 23, 1999
- MONEP SA, October 26, 1998
- Mercato Italiano dei Derivati - IDEM Equity and Index Options, September 1, 1998
- Société de Compensation des Marchés Conditionnels, June 17, 1996
- London International Financial Futures and Options Exchange ("LIFFE"), March 6, 1996
- Hang Seng Index Options, September 26, 1995
- London International Financial Futures Exchange and London Traded Options Market, May 1, 1992
- London Traded Options Market, September 4, 1990
Keep and Preserve Paper Copies – Rule 17a-1
- Investors Exchange LLC, March 1, 2018
- NASDAQ Stock Market LLC, August 1, 2006
Multiple Section Relief
(e.g. exchange traded funds and other basket products)
- Fidelity Covington Trust, May 19, 2020; see also Fidelity Covington Trust Request Letter
- Brandes Investment Trust, November 20, 2018
- Causeway ETMF Trust, November 20, 2018
- iShares U.S. ETF Trust, May 29, 2018
- Calvert Management Series, December 21, 2017
- Hartford Funds NextShares Trust, December 21, 2017
- Additional Limited Exemptions for First Trust Dorsey Wright Focus 5 ETF, January 15, 2015
- BOX Market LLC, May 11, 2012; see also Order Granting Exemption, Release No. 34-66976
- WisdomTree Emerging Markets Corporate Bond Fund, April 16, 2012
- PIMCO Total Return Exchange-Traded Fund, March 1, 2012
- Claymore Exchange-Traded Fund Trust, December 16, 2011
- AdvisorShares Trust, December 16, 2011
- iShares Trust Equity-Index Exchange Traded Fund, November 3, 2011
- WisdomTree Global Real Return Fund, August 29, 2011
- WisdomTree Asia Local Debt Fund, August 16, 2011
- WisdomTree Managed Futures Strategy Fund, August 16, 2011
- AdvisorShares Madrona & Meidell ETFs, June 16, 2011
- Claymore Exchange-Traded Fund Trust, May 24, 2011
- AdvisorShares Sim Income & Growth ETF, February 8, 2011
- AdvisorShares Active Bear ETF, January 19, 2011
- AdvisorShares Trust Actively Managed ETF, December 16, 2010
- AdvisorShares Cambria Global Tactical ETF, October 20, 2010
- PIMCO ETF Trust - Actively Managed ETF, September 22, 2010
- Boston Options Exchange, September 3, 2010
- WisdomTree Trust Dreyfus Commodity Currency Fund an Actively Managed ETF, September 2, 2010
- iShares Trust Equity-Index Exchange Traded Funds, August 17, 2010
- WisdomTree Trust Emerging Markets Local Debt Fund an Actively Managed ETF, August 6, 2010
- AdvisorShares Mars Hill Global Relative Value Actively Managed ETF, July 2, 2010
- AdvisorShares Trust Actively-Managed ETF, WCM/BNY Mellon Focused Growth ADR, June 18, 2010
- WisdomTree Trust Real Return Actively Managed ETF, May 27, 2010
- U.S. One Trust Actively-Managed ETF of ETFs, May 4, 2010
- Grail Advisors ETF Trust Actively Managed Fixed Income ETF, January 27, 2010
- WisdomTree Trust Index-Based ETF of ETFs, December 23, 2009
- iShares Diversified Alternatives Trust Actively-Managed Commodity-Based Investment Vehicle, November 12, 2009
- PIMCO ETF Trust Actively Managed Fixed Income ETF, November 10, 2009
- Grail Advisors ETF Trust – Actively Managed ETF, September 28, 2009
- AdvisorShares Trust Actively-Managed ETF of ETFs and Exchange Traded Products, September 14, 2009
- PIMCO ETF Trust, August 20, 2009
- PIMCO ETF Trust, June 1, 2009
- Grail Advisors ETF Trust, April 30, 2009
- Index IQ ETF Trust, March 25, 2009
- WisdomTree Trust Dreyfus Emerging Currency Fund, January 7, 2009
- Direxion Shares ETF Trust, December 15, 2008
- PowerShares Actively Managed Exchange-Traded Fund Trust, November 14, 2008
- AirShares EU Carbon Allowances Fund and XShares Advisors LLC, November 10, 2008
- Direxion Shares ETF Trust, October 30, 2008
- MACRO Securities Depositor, LLC, July 1, 2008
- WisdomTree Trust, May 9, 2008
- Rydex ETF Trust, April 24, 2008
- PowerShares Actively Managed ETF Trust, April 4, 2008
- Bear Stearns Active ETF Trust, March 24, 2008
- Rydex ETF Trust, October 31, 2007
- Deutsche Bank AG (Exchange-traded Notes), October 12, 2007
- Ameristock ETF Trust, June 29, 2007
- Combination Exchange-traded Funds, June 27, 2007
- Class Relief for Fixed Income Exchange-Traded Funds, April 9, 2007
- HealthShares Composite Exchange-Traded Fund, March 8, 2007
- Chicago Board Options Exchange, Inc., February 23, 2007
- ProShares Trust, January 24, 2007
- HealthShares Emerging Cancer Exchange-Traded Fund and HealthShares Cardio Devices Exchange-Traded Fund, January 22, 2007
- iShares Lehman Short Treasury Bond Fund, iShares Lehman 3-7 Year Treasury Bond Fund, iShares Lehman 10-20 Year Treasury Bond Fund, iShares Lehman 1-3 Year Credit Bond Fund, iShares Lehman Intermediate Credit Bond Fund, iShares Lehman Credit Bond Fund, iShares Lehman Intermediate Government/Credit Bond Fund, iShares Lehman Government/Credit Bond Fund and iShares Lehman MBS Fixed-Rate Bond Fund, December 22, 2006
- MACRO Securities Depositor, LLC, December 22, 2006
- National Stock Exchange, November 28, 2006
- Class Relief for Exchange Traded Index Funds, October 24, 2006
- American Stock Exchange LLC, October 12, 2006
- WisdomTree Trust, October 12, 2006
- iPath Securities — Exchange-Traded Notes, July 27, 2006
- Commodity-based Investment Vehicles Class Letter, June 21, 2006
- ProShares Trust, June 20, 2006
- WisdomTree Trust, June 15, 2006
- iPath Securities — Index-Linked Securities, May 30, 2006
- DB Commodity Index Tracking Fund and DB Commodity Services LLC, January 19, 2006
- Euro Currency Trust, December 5, 2005
- PowerShares Lux Nanotech Portfolio, October 25, 2005
- iShares, August 4, 2005
- Vanguard Emerging Markets Stock Index Fund, Vanguard European Stock Index Fund and Vanguard Pacific Stock Index Fund, March 9, 2005
- PowerShares WilderHill Clean Energy Portfolio, March 2, 2005
- iShares FTSE/Xinhua China 25 Index Fund, October 8, 2004
- Nasdaq Stock Market, Inc., November 13, 2002
- Treasury FITR Exchange Traded Funds, November 1, 2002
- Fresco Index Shares Funds, October 21, 2002
- iShares Trust ("Trust"), iShares 1-3 Year Treasury Index Fund, iShares 7-10 Year Treasury Index Fund, iShares 20+ Year Treasury Index Fund, iShares Treasury Index Fund, iShares Government/Credit Index Fund, iShares Lehman Corporate Bond Fund, and iShares Goldman Sachs InvesTop Corporate Bond Fund, July 15, 2002
- Biotech Boxes, March 19, 2002
- Exemptive Relief for Exchange Traded Index Funds, August 17, 2001
Municipal Auction Rate Securities
- Municipal Auction Rate Securities, March 14, 2008
Municipal Securities Brokers and Dealers
- The State of Oregon, October 4, 2005
- Kentucky Public Employees' Deferred Compensation Authority, July 8, 2002
- Dominion Resources, Inc., March 7, 2000 (A copy of the Dominion Resources letters from 1985 is posted by Westlaw with permission of Thompson Reuters.)
Municipal Securities Disclosure – Rule 15c2-12
- NetRoadshow, Inc., January 29, 2013
- Bloomberg L.P., June 10, 2009
- DPC Data Inc., June 10, 2009
- Interactive Data Corporation, June 10, 2009
- Standard & Poor's Securities Evaluations, Inc., June 10, 2009
- Digital Assurance Certification L.L.C., September 21, 2001
- Clark Street Capital, Inc., August 20, 2003
- Bion Environmental Technologies, Inc., March 18, 2003
Regulation Best Interest and Form CRS
- Securities Industry and Financial Markets Association, December 23, 2020
- Financial Information Forum, December 14, 2012
- Certified Financial Planner Board of Standards, Inc., December 11, 2014
- Certified Financial Planner Board of Standards, Inc., March 11, 2011
National Market System Rules, Miscellaneous – Section 11A
- Chicago Board Options Exchange, Inc., October 29, 2009
- Philadelphia Stock Exchange, Inc., January 23, 2007
- Chicago Stock Exchange, Inc., March 16, 2006
- Philadelphia Stock Exchange, Inc., March 8, 2006
- Chicago Stock Exchange, Inc., August 23, 2005
- National Stock Exchange, August 23, 2005
- Chicago Stock Exchange, Inc., July 1, 2005
- Pacific Exchange, Inc., June 29, 2005
- National Stock Exchange, June 28, 2005
- Boston Stock Exchange, Inc., April 1, 2005
- Pacific Exchange, Inc., February 10, 2005
- Boston Stock Exchange, Inc., October 1, 2004
- Boston Stock Exchange, Inc., February 4, 2004
National Market System Plans
- Consolidated Audit Trail Reporting, March 16, 2020
- FINRA, May 13, 2020
- Securities Industry and Financial Markets Association, February 26, 2019
- Securities Industry and Financial Markets Association, Asset Management Group, October 26, 2017
- Carolina Capital Markets, Inc., July 30, 2013
- International Power Group, February 28, 2013
- Murphy & McGonigle, P.C., April 26, 2017
- Chicago Stock Exchange, Inc., October 6, 2015
- Goldman Sachs Execution & Clearing, L.P., October 27, 2014
- FINRA, CBOE and C2, September 6, 2013
- NYSE LLC and NYSE Amex LLC, February 7, 2011
- American Stock Exchange LLC, July 2, 2007
- Securities Industry and Financial Markets Association, July 2, 2007
- Pacific Exchange, Inc., October 13, 2005
- Securities Industry Association, April 15, 2005
- Schiff Hardin LLP, January 3, 2005
- Securities Industry Association, January 3, 2005
- Morgan Stanley and Citigroup Inc., May 12, 2009
Risk Assessment Rules – Rules 17h-1T and 17h-2T
- Securities Industry Association, September 20, 1993; incoming letter
- Chicago Stock Exchange, Inc., July 20, 2006
- NASD, Inc., June 26, 2006
- CurrencyShares British Pound Sterling Trust, CurrencyShares Australian Dollar Trust, CurrencyShares Canadian Dollar Trust, CurrencyShares Mexican Peso Trust, CurrencyShares Swedish Krona Trust, and CurrencyShares Swiss Franc Trust, June 21, 2006
- Instinet Group, LLC, June 15, 2006
- Pacific Exchange, Inc., October 13, 2005
- Securities Industry Association, July 18, 2005
- Instinet Group, LLC, June 8, 2005
- ITG, Inc., April 22, 2005
- Instinet Group, LLC, June 8, 2004
- Harborside Securities, L.L.C., March 16, 2004
- Portfolio System for Institutional Trading, April 23, 2003
- Vie Institutional Services, February 12, 2003
Rule 10b-18, Issuer Repurchases
- NYSE, LLC and NYSE Amex LLC, February 3, 2010
Rule 12d2-2, Removal from Listing and Registration
- NYSE Arca, Inc., January 31, 2007
- NYSE Arca, Inc., December 8, 2006
Rule 14e-5, Purchases Outside a Tender Offer
- Vimpelcom Ltd., February 5, 2010
- Cash Offer of Franco-Nevada Corporation for Common Shares of International Royalty Corporation, December 23, 2009
- Chemoil Energy Limited, December 14, 2009
- Kraft Foods, Inc., December 9, 2009
- ShareGift USA, December 3, 2008
- MS&Co. OTC Swap Transactions Referencing a Merger Arbitrage Index, December 1, 2008
- Cash Tender Offer by International Business Machines Corporation for Ordinary Shares and ADSs of ILOG S.A., October 9, 2008
- Auction Rate Securities — Global Exemptive Relief, September 22, 2008
- Petersen Energía Inversora, S.A., September 9, 2008
- Loews Corporation, March 27, 2008
- Reuters Group PLC and Thomson Reuters PLC, February 29, 2008
- PT Media Nusantara Tbk, December 18, 2007
- SAP AG, December 5, 2007
- Royal Bank of Scotland Group plc, July 20, 2007
- Grupo Aeropotuario del Sureste, May 9, 2007
- Barclays/ABN AMRO, April 24, 2007
- CANTV, April 6, 2007
- Cleary Gottlieb Steen & Hamilton LLP, April 4, 2007
- Allianz SE, March 27, 2007
- STATS ChipPAC Ltd., March 15, 2007
- Sulzer AG, March 2, 2007
- Asia Satellite Communications Holdings Limited, March 1, 2007
- Exemptive Relief for Purchases Pursuant to Statutory Puts in Japanese Tender Offers, February 20, 2007
- Suzlon Energy Limited, February 9, 2007
- ProSiebenSat.1 Media AG, January 30, 2007
- Nippon Katan, January 26, 2007
- Areva S.A., January 22, 2007
- Hurriyet Invest, January 22, 2007
- Pfleiderer AG, January 12, 2007
- Offer by Crucell N.V. for Shares of Berna Biotech A.G., January 5, 2006
- CenterPoint Energy, December 21, 2006
- Heat Beteiligungs III GmbH, December 20, 2006
- Gallaher Group plc, December 15, 2006
- Companhia Sidenúrgica Nacional, December 1, 2006
- UCB SA, November 29, 2006
- Nasdaq Stock Market, Inc., November 20, 2006
- MEIF II, November 3, 2006
- Barrick Gold Corporation, October 10, 2006
- Gondola Holdings plc, October 2, 2006
- TPO Investments AS, September 18, 2006
- UBS AG, July 13, 2006
- PMI Group, Inc., July 6, 2006
- Associated British Ports Holdings plc, June 22, 2006
- Mittal Steel Company N.V, June 22, 2006
- Associated British Ports Holdings plc, June 8, 2006
- AstraZeneca PLC, May 23, 2006
- Investor AB, April 6, 2006
- Scottish Power plc, April 3, 2006
- Grupo Ferrovial, SA, March 23, 2006
- Gas Natural SDG, S.A., March 2, 2006
- Fresenius Medical Care AG, January 13, 2006
- Gas Natural SDG,, November 18, 2005
- Old Mutual PLC for Försäkringsaktiebolaget Skandia, October 26, 2005
- Macquarie Airports Copenhagen ApS for Kobenhavns Lufthavne A/S, October 24, 2005
- Profit Eagle Limited, October 11, 2005
- Axel Springer AG, September 12, 2005
- Skadden, Arps, Slate, Meagher & Flom (UK) LLP, August 5, 2005
- Compagnie de Saint-Gobain, July 29, 2005
- Barclays Bank PLC for Absa Group Limited, April 4, 2005
- Freshfields Bruckhaus Deringer, March 17, 2005
- Sullivan & Cromwell LLP, December 15, 2005
- United Technologies Corporation for Kidde plc, December 15, 2004
- GmbH for P & I Personal & Informatik Aktiengesellscaft, June 24, 2004
- UCB S.A., May 19, 2004
- SABMiller PLC, May 10, 2004
- Anheuser-Busch Companies, Inc., May 7, 2004
- Songbird Acquisition Limited, April 22, 2004
- BLB Investors, L.L.C., March 31, 2004
- Canary Wharf Group plc, February 9, 2004
- Banco Bilbao Vizcaya Argentaria, S.A. for Series B Shares and American Depository Shares of Grupo Financiero BBVA Bancomer, S.A. de C.V., February 2, 2004
- Matsushita Electric Works, Ltd., December 19, 2003
- Banyu Pharmaceutical Co. Ltd., September 12, 2003
- Rizzoli Corriere della Sera Medical Group S.p.A. for Fila Holding S.p.A.., July 28, 2003
- Twins Acquisition, Inc. Offer for IDS Group plc, June 25, 2003
- Serono France Holding S.A., May 14, 2003
- Vodafone Group Plc, March 3, 2003
- UBS AG, London Branch and J.P. Morgan Securities Limited, February 21, 2003
- Banyu Pharmaceutical Co. Ltd., January 9, 2003
- Offer by CIBER (UK) for ECsoft Group plc, January 8, 2003
- Bank of Ireland Abby National, October 16, 2002
- Pepsi Bottling Group, Inc., Bottling Group LLC and PBG Grupo Embotellador Hispano-Mexicano S.L., October 14, 2002
- Bank of Ireland Abby National, October 8, 2002
- Serono S.A. Offer for All Outstanding Ordinary Shares, ADSs, OCEANEs and Warrants of Genset, September 12, 2002
- Koninklijke Ahold N.V.'s Tender Offer for Shares and ADSs of Santa Isabel S.A., September 10, 2002
- DB Sechste Vermögensverwaltungsgesellschaft mbH for Stinnes AG, August 29, 2002
- Saipem SpA, July 29, 2002
- Kingfisher Plc Offer for Castorama Dubois Investissements SCA, June 4, 2002
- RWE Aktiengesellschaft, March 22, 2002
- Telex-Chile, S.A., March 5, 2002
Rule 15c2-4, Transmission or Maintenance of Payments Received in Connection with Underwritings
- FolioFN, July 15, 2015
- Reliance Trust Company, March 29, 2005
Rule 15c2-11, Initiation of Quotations
- Amended Rule 15c2-11 in Relation to Fixed Income Securities, November 22, 2024
- Rule 15c2-11 Fixed Income No-Action Letter to FINRA, November 30, 2022
- Rule 15c2-11 Fixed Income No-Action Letter 2, December 16, 2021
- Rule 15c2-11 Fixed Income, September 24, 2021
- Nasdaq Stock Market LLC/The Portal® Market, July 31, 2007
- NASD Regulation, Inc., September 10, 2004
- NASD Regulation, Inc., December 1, 1998
- NASD, Inc., December 20, 1993
Rule 17Ad-17, Lost Securityholders and Unresponsive Payees
- Committee of Annuity Insurers, December 23, 2013
Rule 101 of Regulation M,
Activities By Distribution Participants
- Banco Bilbao Vizcaya Argentaria, S.A., August 26, 2019
- Banco Santander, S.A., August 2, 2019
- iShares Preferred Equity Index-Linked ETFs, December 3, 2018
- Invesco Capital Management LLC, September 20, 2018
- ETF Managers Capital LLC, August 8, 2018
- Spotify Technology, S.A., March 23, 2018
- Banco Bilbao Vizcaya Argentaria, S.A., November 3, 2017
- Banco Santander, S.A., June 29, 2017
- Royal Bank of Canada, April 21, 2015
- ING Groep N.V., April 7, 2015
- The Hongkong and Shanghai Banking Corporation Limited and HSBC Bank plc, March 24, 2015
- Republic of Argentina, May 17, 2010
- Shinhan Financial Group Co., Ltd., March 5, 2009
- Republic of Uruguay, June 24, 2008
- Key Hospitality Acquisition Corporation, October 12, 2005
- Banco Santander Central Hispano, S.A., September 10, 2004
- Republic of Panama, January 16, 2004
- Federative Republic of Brazil, January 12, 2004
- Allianz AG, April 10, 2003
- Republic of Colombia, December 2, 2002
- Votorantim Celulose e Papel S.A., June 18, 2002
- Regulation M — Sovereign Bond Exemption, January 12, 2000
Rule 102 of Regulation M,
Activities By Issuers and Selling Security Holders During a Distribution
- NatWest Group plc, May 10, 2021
- Banco Bilbao Vizcaya Argentaria, S.A., August 26, 2019
- Banco Santander, S.A., August 2, 2019
- iShares Preferred Equity Index-Linked ETFs, December 3, 2018
- Invesco Capital Management LLC, September 20, 2018
- ETF Managers Capital LLC, August 8, 2018
- Royal Bank of Scotland Group plc, June 4, 2018
- Spotify Technology, S.A., March 23, 2018
- Banco Bilbao Vizcaya Argentaria, S.A., November 3, 2017
- Banco Santander, S.A., June 29, 2017
- Deutsche Bank Aktiengesellschaft, March 17, 2017
- Canadian Imperial Bank of Commerce, October 31, 2016
- Royal Bank of Scotland Group plc, August 8, 2016
- National Bank of Greece, November 13, 2015
- Royal Bank of Scotland Group, plc, August 3, 2015
- Royal Bank of Scotland Group, plc (AT1 Offering), August 3, 2015
- Royal Bank of Canada, April 21, 2015
- ING Groep N.V., April 7, 2015
- Banco Santander, S.A, January 6, 2015
- Banco Bilbao Vizcaya Argentaria, S.A, November 17, 2014
- UBS AG, October 7, 2014
- Banco Santander, S.A., September 18, 2014
- Jones Lang LaSalle Income Property Trust , August 26, 2014
- Deutsche Bank Aktiengesellschaft, June 4, 2014
- Barclays PLC, May 14, 2014
- National Bank of Greece, May 7, 2014
- Lloyds Banking Group plc, March 25, 2014
- Lloyds Banking Group plc, March 6, 2014
- Barclays PLC, November 7, 2013
- Lloyds Banking Group plc, September 16, 2013
- Barclays PLC, July 31, 2013
- IMH Financial Corporation, July 17, 2013
- FS Energy and Power Fund, January 10, 2012
- Bank of Ireland, June 7, 2011
- Bank of Montreal, April 8, 2011
- Sumitomo Mitsui Financial Group, Inc., February 7, 2011
- Banco Bilbao Vizcaya Argentaria, S.A., October 28, 2010
- Deutsche Bank Aktiengesellschaft, September 16, 2010
- The Toronto-Dominion Bank, August 19, 2010
- Bank of Ireland, April 22, 2010
- ING, November 19, 2009
- Lloyds Banking Group plc, November 2, 2009
- FS Investment Corporation, April 20, 2009
- Lloyds Banking Group plc, April 20, 2009
- Shinhan Financial Group Co., Ltd., March 5, 2009
- The Royal Bank of Scotland Group plc and ABN AMRO Holding N.V., February 18, 2009
- Banco Santander, S.A., December 22, 2008
- Banco Santander, S.A., November 7, 2008
- Lloyds TSB Group plc, October 21, 2008
- Royal Bank of Scotland Group plc and ABN AMRO Holding N.V., October 17, 2008
- Banco Santander, S.A., August 18, 2008
- Barclays PLC, June 16, 2008
- UBS AG, May 16, 2008
- UBS AG, April 22, 2008
- Royal Bank of Scotland Group plc and ABN AMRO Holding N.V, April 21, 2008
- Toronto-Dominion Bank, December 21, 2007
- Class Relief for Real Estate Investment Trust Share Redemption Programs, October 22, 2007
- REITPlus, Inc., October 9, 2007
- ABN AMRO Holding N.V., , August 7, 2007
- Barclays PLC, August 7, 2007
- Barclays PLC, August 2, 2007
- Banco Santander Central Hispano, S.A., July 23, 2007
- Fortis SA/NV and Fortis NV, July 23, 2007
- Royal Bank of Scotland Group plc, July 23, 2007
- Banco Bilbao Vizcaya Argentaria, S.A, June 25, 2007
- Cole Credit Property Trust II, April 11, 2007
- Allianz SE, March 23, 2007
- UnumProvident Corporation, Inc., February 8, 2007
- Hines Real Estate Investment Trust, Inc., September 7, 2006
- NNN Healthcare/Office REIT, Inc., August 24, 2006
- Dividend Capital Total Realty Trust Inc., January 31, 2006
- United Development Funding III, LP, January 11, 2006
- Key Hospitality Acquisition Corporation, October 12, 2005
- Lend Lease Corporation Limited, October 15, 2004
- Paladin Realty Income Properties, Inc., October 14, 2004
- TECO Energy, Inc., October 8, 2004
- Hughes Supply, Inc., October 4, 2004
- Banco Santander Central Hispano, S.A., September 10, 2004
- Orange Hospitality, Inc., September 9, 2004
- CNL Retirement Properties, Inc., May 19, 2004
- Associated Grocers of Maine, Inc., May 6, 2004
- CNL Income Properties, Inc., March 11, 2004
- Wells Real Estate Investment Trust II, Inc., December 9, 2003
- ING Senior Income Fund, October 9, 2003
- Inland Western Retail Real Estate Trust, Inc., August 25, 2003
- Allianz AG, April 10, 2003
- ING Senior Income Fund, October 17, 2002
- Popular High Grade Fixed-Income Fund, September 10, 2002
- Chicago Stock Exchange, Inc., October 6, 2004
- iShares COMEX Gold Trust®, January 27, 2005
- streetTRACKS Gold Trust®, November 17, 2004
- Market XT, August 8, 2002
- Herbruck, Alder & Co., May 3, 2002
- Marex Securities Products Inc., February 26, 2025
- Capitolis Liquid Global Markets LLC, March 13, 2023
- SIFMA, February 23, 2022
- Morgan Stanley Europe SE, December 22, 2021
- Macquarie Bank Limited, November 19, 2021
- Canadian Banks Association, November 1, 2021
- Skandinaviska Enskilda Banken AB, November 1, 2021
- Securities Industry and Financial Markets Association, October 27, 2021
- International Swaps and Derivatives Association and Securities Industry and Financial Markets Association, August 5, 2021
- International Swaps and Derivatives Association and Securities Industry and Financial Markets Association, August 5, 2021
Security Futures Products Brokers and Dealers
- National Futures Association, April 11, 2005
- National Futures Association, March 22, 2004
- Silver Young Trading LLC, June 25, 2003
- Notice Registration Requirements, March 5, 2002
- Securities Industry Association and Futures Industry Association, August 20, 2002
- Equiniti Trust Company, July 29, 2021
- Computershare Investor Services (Jersey) Limited and Computershare Trust Company, N .A., November 14, 2013
- Securities Information Center, March 31, 2010
- TIAA-CREF, May 2, 2008
- Wells Fargo Bank, N.A., July 29, 2004
- Lincoln National Life Insurance Company, August 22, 2003
Vendor Display Rule Interpretive Guidance
- BATS Global Markets, Inc., July 22, 2015
- Nasdaq Stock Market, Inc., July 23, 2002
Selected Class Letters
- Class Relief for Real Estate Investment Trust Share Redemption Programs, October 22, 2007
- Combination Exchange-traded Funds, June 27, 2007
- Class Relief for Fixed Income Exchange-Traded Funds, April 9, 2007
- Cleary Gottlieb Steen & Hamilton LLP, April 4, 2007 (Financial Advisors)
- Sulzer AG, March 2, 2007 (Offerors)
- Exemptive Relief for Purchases Pursuant to Statutory Puts in Japanese Tender Offers, February 20, 2007
- Class Relief for Exchange Traded Index Funds, October 24, 2006 (Update of August 17, 2001, letter)
- Mittal Steel Company N.V, June 22, 2006 (Dual Offers)
- Commodity-based Investment Vehicles Class Letter, June 21, 2006
- Exemptive Relief for Exchange Traded Index Funds, August 17, 2001
- Regulation M — Sovereign Bond Exemption, January 12, 2000
Alphabetical List of No-Action Letters
- 1st Global, Inc., May 7, 2001
- 2000 Vadala (Marketability of Certain Securities) Letter Update, August 18, 2022
- ABN AMRO Holding N.V., , August 7, 2007
- Acqua Wellington North America Equities Fund, Ltd., July 11, 2001
- ADP TotalSource, Inc., December 4, 2007
- AdvisorShares Active Bear ETF, January 19, 2011
- AdvisorShares Cambria Global Tactical ETF, October 20, 2010
- AdvisorShares Madrona & Meidell ETFs, June 16, 2011
- AdvisorShares Mars Hill Global Relative Value Actively Managed ETF, July 2, 2010
- AdvisorShares Sim Income & Growth ETF, February 8, 2011
- AdvisorShares Trust, December 16, 2011
- AdvisorShares Trust Actively Managed ETF, December 16, 2010
- AdvisorShares Trust Actively-Managed ETF of ETFs and Exchange Traded Products, September 14, 2009
- AdvisorShares Trust Actively-Managed ETF, WCM/BNY Mellon Focused Growth ADR, June 18, 2010
- AirShares EU Carbon Allowances Fund and XShares Advisors LLC, November 10, 2008
- Allianz SE, March 27, 2007
- Allianz SE, March 23, 2007
- Allianz AG, April 10, 2003
- A.M. Best Company, Inc., March 3, 2005
- Amended Rule 15c2-11 in Relation to Fixed Income Securities, November 22, 2024
- American Stock Exchange, July 9, 2002
- American Stock Exchange LLC, July 2, 2007
- American Stock Exchange LLC, October 12, 2006
- Ameristock ETF Trust, June 29, 2007
- AngelList LLC, March 28, 2013
- Anheuser-Busch Companies, Inc., May 7, 2004
- Areva S.A., January 22, 2007
- Asia Satellite Communications Holdings Limited, March 1, 2007
- Associated British Ports Holdings plc, June 22, 2006
- Associated British Ports Holdings plc, June 8, 2006
- Associated Grocers of Maine, Inc., May 6, 2004
- AstraZeneca PLC, May 23, 2006
- ASX Limted, August 13, 2007
- Attain System, October 7, 2005
- Attain System, January 6, 2005
- Attain Systems, April 1, 2004
- Attkisson, Carter, & Akers, June 23, 1998
- AUTOM System, April 15, 2002
- Average Price, Multiple Capacity Confirmations, March 3, 2005
- Axel Springer AG, September 12, 2005
- Banco Bilbao Vizcaya Argentaria, S.A., August 26, 2019
- Banco Bilbao Vizcaya Argentaria, S.A., November 3, 2017
- Banco Bilbao Vizcaya Argentaria, S.A, November 17, 2014
- Banco Bilbao Vizcaya Argentaria, S.A., October 28, 2010
- Banco Bilbao Vizcaya Argentaria, S.A, June 25, 2007
- Banco Bilbao Vizcaya Argentaria, S.A. for Series B Shares and American Depository Shares of Grupo Financiero BBVA Bancomer, S.A. de C.V., February 2, 2004
- Banco Santander, S.A., August 2, 2019
- Banco Santander, S.A, June 29, 2017
- Banco Santander, S.A, January 6, 2015
- Banco Santander, S.A., September 18, 2014
- Banco Santander, S.A., December 22, 2008
- Banco Santander, S.A., November 7, 2008
- Banco Santander, S.A., August 18, 2008
- Banco Santander Central Hispano, S.A., July 23, 2007
- Banco Santander Central Hispano, S.A., September 10, 2004
- BancWest Investment Services, Inc., March 21, 2019
- Bank of Ireland, June 7, 2011
- Bank of Ireland, April 22, 2010
- Bank of Ireland Abby National, October 16, 2002
- Bank of Ireland Abby National, October 8, 2002
- Bank of Montreal, April 8, 2011
- Banyu Pharmaceutical Co. Ltd., January 9, 2003
- Banyu Pharmaceutical Co. Ltd., September 11, 2003
- Barclays/ABN AMRO, April 24, 2007
- Barclays Capital Inc., September 19, 2008
- Barclays PLC, May 14, 2014
- Barclays PLC, November 7, 2013
- Barclays PLC, July 31, 2013
- Barclays PLC, June 16, 2008
- Barclays PLC, August 7, 2007
- Barclays PLC, August 2, 2007
- Barclays Bank PLC for Absa Group Limited, April 4, 2005
- Barrick Gold Corporation, October 10, 2006
- BATS Exchange, Inc., February 25, 2010
- BATS Exchange, Inc., October 23, 2008
- BATS Global Markets, Inc., July 22, 2015
- BATS Trading, Inc., June 28, 2006
- BATS Trading, Inc., February 17, 2006
- BATS Trading, Inc., May 8, 2006
- BATS Y-Exchange, Inc., November 27, 2012
- BATS Y-Exchange, October 12, 2010
- Bear, Stearns & Co. Inc.; CS First Boston corporation; CSFP Capital, Inc.; Goldman, Sachs & Co.; Lehman Brothers Inc.; Morgan Stanley & Co. Incorporated; and Salomon Brothers Inc, January 30, 1996
- Bear Stearns Active ETF Trust, March 24, 2008
- Bion Environmental Technologies, Inc., March 18, 2003
- Biotech Boxes, March 19, 2002
- BLB Investors, L.L.C., March 31, 2004
- Bloomberg L.P., November 24, 2015
- Bloomberg L.P., June 10, 2009
- Bloomberg Tradebook, April 1, 2004
- Bloomberg Tradebook LLC, June 28, 2006
- Bloomberg Tradebook LLC, November 17, 2005
- Bloomberg Tradebook LLC and Calyon Inc., December 31, 2007
- BNY Mellon, December 31, 2009
- Borsa Italiana S.p.A., September 24, 2004
- Boston Options Exchange, September 3, 2010
- Boston Stock Exchange, December 23, 2008
- Boston Stock Exchange, November 8, 2006
- Boston Stock Exchange, Inc., April 1, 2005
- Boston Stock Exchange, Inc., October 1, 2004
- Boston Stock Exchange, Inc., February 4, 2004
- BOX Market LLC, May 11, 2012; see also Order Granting Exemption, Release No. 34-66976
- BOX Options Exchange, May 11, 2012; see also Order Granting Exemption, Release No. 34-66976
- Brandes Investment Trust, November 20, 2018
- Brumberg, Mackey & Wall, P.L.C., May 17, 2010
- BRUT System, January 6, 2005
- BRUT System, April 1, 2004
- BRUT ECN, LLC, February 1, 2002
- Calvert Management Series, December 21, 2017
- Canadian Banks Association, November 1, 2021
- Canadian Imperial Bank of Commerce, October 31, 2016
- Canadian Stock Transfer Company Inc., March 4, 2015
- Canadian Stock Transfer Company Inc., March 4, 2014
- Canadian Stock Transfer Company Inc., March 4, 2013
- Canary Wharf Group plc, February 9, 2004
- CANTV, April 6, 2007
- Capitolis Liquid Global Markets LLC, March 13, 2023
- Carolina Capital Markets, Inc., July 30, 2013
- Capital Institutional Services, Inc., April 13, 2007
- Cash Offer of Franco-Nevada Corporation for Common Shares of International Royalty Corporation, December 23, 2009
- Causeway ETMF Trust, November 20, 2018
- Cboe Exchange, Inc., Re: Treatment of Certain Corporate Bond Index Futures under Appendix A to Rule 15c3-1, December 6, 2024
- CenterPoint Energy, December 21, 2006
- Century Business Services, Inc. and CBIZ Financial Solutions, Inc., March 1, 2002
- Certified Financial Planner Board of Standards, Inc., March 11, 2011
- Charles Schwab, Inc., August 23, 2012
- Charles Schwab & Co., Inc., February 3, 2012
- Charles Schwab & Co., Inc., November 27, 1996
- Chemoil Energy Limited, December 14, 2009
- Chicago Board Options Exchange, Inc., October 29, 2009
- Chicago Board Options Exchange, Inc., February 23, 2007
- Chicago Board Options Exchange, Inc., July 12, 2004
- Chicago Board Options Exchange, March 31, 2003
- Chicago Board Options Exchange, Inc. and Financial Industry Regulatory Authority, Inc., May 4, 2012
- Chicago Mercantile Exchange Inc., January 15, 2016
- Chicago Stock Exchange, Inc., October 6, 2015
- Chicago Stock Exchange, Inc., November 15, 2007
- Chicago Stock Exchange, Inc., July 20, 2006
- Chicago Stock Exchange, Inc., March 16, 2006
- Chicago Stock Exchange, Inc., August 23, 2005
- Chicago Stock Exchange, Inc., July 1, 2005
- Chicago Stock Exchange, Inc., October 6, 2004
- Chubb Securities Corporation November 24, 1993
- Citigroup Global Markets Inc., August 28, 2019
- Clark Street Capital, Inc., August 20, 2003
- Class Relief for Exchange Traded Index Funds, October 24, 2006
- Class Relief for Fixed Income Exchange-Traded Funds, April 9, 2007
- Class Relief for Real Estate Investment Trust Share Redemption Programs, October 22, 2007
- Claymore Exchange-Traded Fund Trust, December 16, 2011
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- Direct Edge ECN LLC Purchase of ATTAIN ECN, October 21, 2005
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- EDGX Exchange, May 26, 2010
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- Financial Industry Regulatory Authority (Definition of "Fully Paid Securities" under Rule 15c3-3), September 28, 2017
- Financial Industry Regulatory Authority (Net Capital Treatment of Certain U.S. Treasury Exchange-Traded Funds), June 2, 2022
- Financial Industry Regulatory Authority, October 29, 2018
- Financial Industry Regulatory Authority, January 27, 2017
- Financial Industry Regulatory Authority, Inc., December 10, 2012
- Financial Industry Regulatory Authority, September 1, 2009
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- Financial Information Forum, December 14, 2012
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- FINRA, CBOE and C2, September 6, 2013
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- Fresco Index Shares Funds, October 21, 2002
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- Fresenius Medical Care AG, January 13, 2006
- FS Energy and Power Fund, January 10, 2012
- FSC Securities Corporation, January 30, 2007
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- Hurriyet Invest, January 22, 2007
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- ING Senior Income Fund, October 17, 2002
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- Inet ECN, April 2, 2004
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- International Swaps and Derivatives Association and Securities Industry and Financial Markets Association, August 5, 2021
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See also: Order Granting Exemption, Release No. 34-89790 - John W. Loofbourrow Associates, Inc., June 29, 2006
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- Representation Letter from LSE Derivatives, November 12, 2014
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- Market XT, March 29, 2002
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See also: Order Granting Exemption, Release No. 34-89926 - Mercato Italiano dei Derivati - IDEM Equity and Index Options, September 1, 1998
- MIAX PEARL, LLC, September 21, 2020
See also: Order Granting Exemption, Release No. 34-89942 - Mittal Steel Company N.V, June 22, 2006
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- National Futures Association, March 22, 2004
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- National Stock Exchange, June 28, 2005
- National Stock Exchange, August 23, 2005
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- Royal Bank of Scotland Group plc and ABN AMRO Holding N.V., October 17, 2008
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- Securities Industry and Financial Markets Association, January 11, 2010
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- Securities Industry and Financial Markets Association, January 10, 2008
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- Securities Industry and Financial Markets Association, December 29, 2006
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- Securities Industry Association, July 18, 2005
- Securities Industry Association, April 15, 2005
- Securities Industry Association, February 10, 2005
- Securities Industry Association, January 3, 2005
- Securities Industry Association, February 12, 2004
- Securities Industry Association, September 21, 2001
- Securities Industry Association, April 12, 2001
- Securities Industry Association, March 12, 2001
- Securities Industry Association, September 20, 1993; incoming letter
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- Select Sector SPDRs, November 22, 2005
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- Serono S.A. Offer for All Outstanding Ordinary Shares, ADSs, OCEANEs and Warrants of Genset, September 12, 2002
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- Tokyo Stock Exchange, July 27, 1999
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- Vodafone Group Plc, March 3, 2003
- Votorantim Celulose e Papel S.A., June 18, 2002
- Wachovia Securities, April 30, 2007
- Wachovia Securities, August 15, 2006
- WEBS Index Series, November 22, 2005
- Wells Fargo Bank, N.A., July 29, 2004
- Wells Real Estate Investment Trust II, Inc., December 9, 2003
- Welton Street Investments, LLC, June 27, 2006
- William Blair & Company L.L.C., June 10, 2005
- WisdomTree Asia Local Debt Fund, August 16, 2011
- WisdomTree Emerging Markets Corporate Bond Fund, April 16, 2012
- WisdomTree Global Real Return Fund, August 29, 2011
- WisdomTree Managed Futures Strategy Fund, August 16, 2011
- WisdomTree Trust, May 9, 2008
- WisdomTree Trust, October 12, 2006
- WisdomTree Trust, June 15, 2006
- WisdomTree Trust Dreyfus Commodity Currency Fund an Actively Managed ETF, September 2, 2010
- WisdomTree Trust Dreyfus Emerging Currency Fund, January 7, 2009
- WisdomTree Trust Emerging Markets Local Debt Fund an Actively Managed ETF, August 6, 2010
- WisdomTree Trust Index-Based ETF of ETFs, December 23, 2009
- WisdomTree Trust Real Return Actively Managed ETF, May 27, 2010
- Wolff Juall Investments, LLC, May 17, 2005
- Jeffrey A. Wolfson, July 26, 2012
- Robert A. Wolfson, July 26, 2012
- Woodstock Financial Group, Inc., January 14, 2008
- Woodstock Financial Group, Inc., November 7, 2007
Chronological List of No-Action Letters
- Marex Securities Products Inc., February 26, 2025
- Cboe Exchange, Inc., Re: Treatment of Certain Corporate Bond Index Futures under Appendix A to Rule 15c3-1, December 6, 2024
- Securities Industry and Financial Markets Association, December 5, 2024
- Amended Rule 15c2-11 in Relation to Fixed Income Securities, November 22, 2024
- Representation Letter from B3, April 12, 2024
- Representation Letter from NSE IFSC, April 4, 2024
- Representation Letter from Cboe Europe, May 23, 2023
- M&A Brokers, March 29, 2023
- Capitolis Liquid Global Markets LLC, March 13, 2023
- Securities Industry and Financial Markets Association, December 9, 2022
- Rule 15c2-11 Fixed Income No-Action Letter to FINRA, November 30, 2022
- Nasdaq Stockholm, September 19, 2022
- 2000 Vadala (Marketability of Certain Securities) Letter Update, August 18, 2022
- Financial Industry Regulatory Authority (Net Capital Treatment of Certain U.S. Treasury Exchange-Traded Funds), June 2, 2022
- SIFMA, February 23, 2022
- Morgan Stanley Europe SE, December 22, 2021
- Rule 15c2-11 Fixed Income No-Action Letter 2, December 16, 2021
- Macquarie Bank Limited, November 19, 2021
- Canadian Banks Association, November 1, 2021
- Skandinaviska Enskilda Banken AB, November 1, 2021
- Securities Industry and Financial Markets Association, October 27, 2021
- Rule 15c2-11 Fixed Income, September 24, 2021
- Representation Letter from Cboe Europe, September 1, 2021
- International Swaps and Derivatives Association and Securities Industry and Financial Markets Association, August 5, 2021
- International Swaps and Derivatives Association and Securities Industry and Financial Markets Association, August 5, 2021
- Equiniti Trust Company, July 29, 2021
- NatWest Group plc, May 10, 2021
- TMX Group, December 28, 2020; Incoming Letter
- Securities Industry and Financial Markets Association, December 23, 2020
- Representation Letter from National Stock Exchange of India, December 21, 2020
- Securities Industry and Financial Markets Association, December 9, 2020
- Representation Letter from Cboe Europe, November 13, 2020
- Financial Industry Regulatory Authority (Broker-Dealers Borrowing Fully Paid and Excess Margin Securities from Customers) October 22, 2020
- Financial Industry Regulatory Authority (ATS Role in the Settlement of Digital Asset Security Trades) September 25, 2020
- MIAX PEARL, LLC, September 21, 2020
See also: Order Granting Exemption, Release No. 34-89942 - MEMX LLC, September 18, 2020
See also: Order Granting Exemption, Release No. 34-89926 - Long-Term Stock Exchange, Inc., September 9, 2020
See also: Order Granting Exemption, Release No. 34-89790 - Fidelity Covington Trust, May 19, 2020; see also Fidelity Covington Trust Request Letter
- Securities Industry and Financial Markets Association, May 15, 2020; see also Incoming Letter
- FINRA, May 13, 2020
- Consolidated Audit Trail Reporting, March 16, 2020
- Neptune Networks Ltd., March 4, 2020; Incoming Letter
- Representation Letter from Nasdaq Stockholm, January 15, 2020
- Securities Industry and Financial Markets Association, January 8, 2020
- Options Clearing Corporation, November 18, 2019
- Paxos Trust Company, LLC (Time Limited No-Action), October 28, 2019
- Citigroup Global Markets Inc., August 28, 2019
- Banco Bilbao Vizcaya Argentaria, S.A., August 26, 2019
- Banco Santander, S.A., August 2, 2019
- Letter from LSE Derivatives, June 3, 2019
- BancWest Investment Services, Inc., March 21, 2019
- Options Clearing Corporation, February 27, 2019
- Securities Industry and Financial Markets Association, February 26, 2019
- Securities Industry and Financial Markets Association, December 12, 2018
- iShares Preferred Equity Index-Linked ETFs, December 3, 2018
- Brandes Investment Trust, November 20, 2018
- Causeway ETMF Trust, November 20, 2018
- Financial Industry Regulatory Authority, October 29, 2018
- Securities Industry and Financial Markets Association, Re: Treatment of Operating Leases under Rule 5c3-l, October 23, 2018
- Representation Letter from Korea Exchange, September 18, 2018
- SS&C Technologies, Inc., October 2, 2018chron;
- Invesco Capital Management LLC, September 20, 2018
- Financial Information Forum, September 5, 2018
- ETF Managers Capital LLC, August 8, 2018
- Royal Bank of Scotland Group plc, June 4, 2018
- iShares U.S. ETF Trust, May 29, 2018
- Financial Industry Regulatory Authority, April 12, 2018
- Catalyst Corporate Federal Credit Union, April 11, 2018
- Spotify Technology, S.A., March 23, 2018
- National Financial Services LLC, Re: Cash in a Customer Reserve Account under Rule 15c3-3(e)(5), March 8, 2018
- Invesco PowerShares Capital Management LLC, Re: Net Capital Treatment of PowerShares Treasury Collateral Portfolio, March 6, 2018
- Investors Exchange LLC, March 1, 2018
- Securities Industry and Financial Markets Association, Re: Treatment of Revenue from Contracts with Customers under Rule 15c3-1, January 4, 2018
- Calvert Management Series, December 21, 2017
- Hartford Funds NextShares Trust, December 21, 2017
- Banco Bilbao Vizcaya Argentaria, S.A., November 3, 2017
- Securities Industry and Financial Markets Association, Asset Management Group, October 26, 2017
- Financial Industry Regulatory Authority (Definition of "Fully Paid Securities" under Rule 15c3-3), September 28, 2017
- N.I.S. Financial Services, Inc., August 15, 2017
- Banco Santander, S.A., June 29, 2017
- Murphy & McGonigle, P.C., April 26, 2017
- Deutsche Bank Aktiengesellschaft, March 17, 2017
- Financial Industry Regulatory Authority, January 27, 2017
- Securities Industry and Financial Markets Association, December 12, 2016
- National Securities Clearing Corporation, December 1, 2016
- Securities Industry and Financial Markets Association, November 8, 2016
- Canadian Imperial Bank of Commerce, October 31, 2016
- Financial Industry Regulatory Authority, Inc., Re: Treatment under Rule 15c3-l of Margin Posted by Broker-Dealers with Respect to Swaps, August 19, 2016
- Royal Bank of Scotland Group plc, August 8, 2016
- Investors' Exchange LLC, July 26, 2016; see also Order Granting Exemption, Release No. 34-78417
- MML Investors Services, LLC, July 19, 2016
- Financial Industry Regulatory Authority, Inc., re: Definition of "Ready Market" with regard to Foreign Equity Securities pursuant to Rule 15c3-1(c)(11)(i), February 9, 2016
- Representation Letter from Taiwan Futures Exchange, February 2, 2016
- Chicago Mercantile Exchange Inc., January 15, 2016
- Representation Letter from Eurex Deutschland, December 1, 2015
- Bloomberg L.P., November 24, 2015
- National Bank of Greece, November 13, 2015
- Chicago Stock Exchange, Inc., October 6, 2015
- Royal Bank of Scotland Group, plc, August 3, 2015
- Royal Bank of Scotland Group, plc (AT1 Offering), August 3, 2015
- BATS Global Markets, Inc., July 22, 2015
- FolioFN, July 15, 2015
- Royal Bank of Canada, April 21, 2015
- ING Groep N.V., April 7, 2015
- The Hongkong and Shanghai Banking Corporation Limited and HSBC Bank plc, March 24, 2015
- NYLIFE Securities LLC, March 12, 2015
- Canadian Stock Transfer Company Inc., March 4, 2015
- Securities Industry and Financial Markets Association, Re: Certain Amendments to Rule 15c3-3, February 5, 2015
- MarketAxess Corporation, January 26, 2015
- Additional Limited Exemptions for First Trust Dorsey Wright Focus 5 ETF, January 15, 2015
- Securities Industry and Financial Markets Association, January 9, 2015
- Banco Santander, S.A, January 6, 2015
- NASDAQ OMX BX, Inc., November 28, 2014
- Banco Bilbao Vizcaya Argentaria, S.A, November 17, 2014
- Social Finance Inc., November 13, 2014
- Representation Letter from LSE Derivatives, November 12, 2014
- Goldman Sachs Execution & Clearing, L.P., October 27, 2014
- UBS AG, October 7, 2014
- Banco Santander, S.A., September 18, 2014
- Representation Letter from Euronext Amsterdam, September 17, 2014
- Representation Letter from Euronext Brussels, September 17, 2014
- Representation Letter from Euronext Paris, September 17, 2014
- Jones Lang LaSalle Income Property Trust , August 26, 2014
- Deutsche Bank Aktiengesellschaft, June 4, 2014
- Barclays PLC, May 14, 2014
- National Bank of Greece, May 7, 2014
- Representation Letter from ICE Futures Europe, March 28, 2014
- Lloyds Banking Group plc, March 25, 2014
- NYSE Arca, Inc., March 25, 2014
- Lloyds Banking Group plc, March 6, 2014
- Canadian Stock Transfer Company Inc., March 4, 2014
- Financial Industry Regulatory Authority, Re: Broker-Dealers Holding Cash in a Reserve Account at a Non-Affiliated U.S. Branch of a Foreign Bank under Rule 15c3-3, February 26, 2014
- Securities Industry and Financial Markets Association, Re: Certain Amendments to Rule 15c3-3, February 26, 2014
- LCH.Clearnet SA, December 30, 2013
- Committee of Annuity Insurers, December 23, 2013
- Computershare Investor Services (Jersey) Limited and Computershare Trust Company, N .A., November 14, 2013
- LCH.Clearnet SA, September 27, 2013
- Lloyds Banking Group plc, September 16, 2013
- FINRA, CBOE and C2, September 6, 2013
- NYSE Arca, Inc., September 3, 2013
- Barclays PLC, July 31, 2013
- Carolina Capital Markets, Inc., July 30, 2013
- IMH Financial Corporation, July 17, 2013
- LIFFE A&M and Class Relief, July 1, 2013
- Roland Berger Strategy Consultants, May 28, 2013
- Committee of Annuity Insurers, Securities Industry and Financial Markets Association, and American Council of Life Insurers, April 23, 2013
- AngelList LLC, March 28, 2013
- FundersClub Inc. and FundersClub Management LLC, March 26, 2013
- Packerland Brokerage Services, March 18, 2013
- Canadian Stock Transfer Company Inc., March 4, 2013
- International Power Group, February 28, 2013
- The NASDAQ Stock Market LLC, February 15, 2013
- NetRoadshow, Inc., January 29, 2013
- Securities Industry and Financial Markets Association, January 11, 2013
- Securities Industry and Financial Markets Association, December 21, 2012
- Financial Information Forum, December 14, 2012
- Financial Industry Regulatory Authority, Inc., December 10, 2012
- Nomura Securities International Inc., December 10, 2012
- Options Clearing Corporation, November 29, 2012
- BATS Y-Exchange, Inc., November 27, 2012
- Charles Schwab, Inc., August 23, 2012
- Jeffrey A. Wolfson, July 26, 2012
- Robert A. Wolfson, July 26, 2012
- S3 Matching Technologies LP, July 19, 2012
- Ernst & Young Global Ltd., July 12, 2012
- New York Stock Exchange LLC and NYSE Amex LLC, July 3, 2012
- Options Clearing Corporation, June 4, 2012
- BOX Market LLC, May 11, 2012; see also Order Granting Exemption, Release No. 34-66976
- BOX Options Exchange, May 11, 2012; see also Order Granting Exemption, Release No. 34-66976
- Chicago Board Options Exchange, Inc. and Financial Industry Regulatory Authority, Inc., May 4, 2012
- WisdomTree Emerging Markets Corporate Bond Fund, April 16, 2012
- PIMCO Total Return Exchange-Traded Fund, March 1, 2012
- Charles Schwab & Co., Inc., February 3, 2012
- FS Energy and Power Fund, January 10, 2012
- AdvisorShares Trust, December 16, 2011
- Claymore Exchange-Traded Fund Trust, December 16, 2011
- iShares Trust Equity-Index Exchange Traded Fund, November 3, 2011
- WisdomTree Global Real Return Fund, August 29, 2011
- WisdomTree Asia Local Debt Fund, August 16, 2011
- WisdomTree Managed Futures Strategy Fund, August 16, 2011
- Bank of Ireland, June 7, 2011
- AdvisorShares Madrona & Meidell ETFs, June 16, 2011
- Claymore Exchange-Traded Fund Trust, May 24, 2011
- Roadshow Broadcast LLC, May 6, 2011
- Bank of Montreal, April 8, 2011
- Certified Financial Planner Board of Standards, Inc., March 11, 2011
- AdvisorShares Sim Income & Growth ETF, February 8, 2011
- NYSE LLC and NYSE Amex LLC, February 7, 2011
- Sumitomo Mitsui Financial Group, Inc., February 7, 2011
- AdvisorShares Active Bear ETF, January 19, 2011
- Securities Industry and Financial Markets Association, January 11, 2011
- AdvisorShares Trust Actively Managed ETF, December 16, 2010
- Nemzoff & Company, LLC, November 30, 2010
- Omgeo LLC, November 19, 2010
- Banco Bilbao Vizcaya Argentaria, S.A., October 28, 2010
- AdvisorShares Cambria Global Tactical ETF, October 20, 2010
- BATS Y-Exchange, October 12, 2010
- PIMCO ETF Trust - Actively Managed ETF, September 22, 2010
- Deutsche Bank Aktiengesellschaft, September 16, 2010
- NASDAQ OMX PHLX, September 9, 2010
- Boston Options Exchange, September 3, 2010
- WisdomTree Trust Dreyfus Commodity Currency Fund an Actively Managed ETF, September 2, 2010
- The Toronto-Dominion Bank, August 19, 2010
- iShares Trust Equity-Index Exchange Traded Funds, August 17, 2010
- WisdomTree Trust Emerging Markets Local Debt Fund an Actively Managed ETF, August 6, 2010
- AdvisorShares Mars Hill Global Relative Value Actively Managed ETF, July 2, 2010
- AdvisorShares Trust Actively-Managed ETF, WCM/BNY Mellon Focused Growth ADR, June 18, 2010
- Society for Worldwide Interbank Financial Telecommunication, May 27, 2010
- WisdomTree Trust Real Return Actively Managed ETF, May 27, 2010
- EDGA Exchange, May 26, 2010
- EDGX Exchange, May 26, 2010
- Brumberg, Mackey & Wall, P.L.C., May 17, 2010
- Republic of Argentina, May 17, 2010
- The Investment Archive, LLC, May 14, 2010
- U.S. One Trust Actively-Managed ETF of ETFs, May 4, 2010
- Bank of Ireland, April 22, 2010
- Securities Information Center, March 31, 2010
- BATS Exchange, Inc., February 25, 2010
- Vimpelcom Ltd., February 5, 2010
- NYSE, LLC and NYSE Amex LLC, February 3, 2010
- Grail Advisors ETF Trust Actively Managed Fixed Income ETF, January 27, 2010
- Securities Industry and Financial Markets Association, January 11, 2010
- BNY Mellon, December 31, 2009
- Putnam Investor Services, Inc., December 31, 2009
- Cash Offer of Franco-Nevada Corporation for Common Shares of International Royalty Corporation, December 23, 2009
- WisdomTree Trust Index-Based ETF of ETFs, December 23, 2009
- Chemoil Energy Limited, December 14, 2009
- Kraft Foods, Inc., December 9, 2009
- ING, November 19, 2009
- iShares Diversified Alternatives Trust Actively-Managed Commodity-Based Investment Vehicle, November 12, 2009
- PIMCO ETF Trust Actively Managed Fixed Income ETF, November 10, 2009
- Lloyds Banking Group plc, November 2, 2009
- Chicago Board Options Exchange, Inc., October 29, 2009
- Grail Advisors ETF Trust – Actively Managed ETF, September 28, 2009
- AdvisorShares Trust Actively-Managed ETF of ETFs and Exchange Traded Products, September 14, 2009
- Financial Industry Regulatory Authority, September 1, 2009
- Federal Reserve Board New York, August 21, 2009
- PIMCO ETF Trust, August 20, 2009
- LIFFE Administration and Management, July 29, 2009
- Bloomberg L.P., June 10, 2009
- DPC Data Inc., June 10, 2009
- Interactive Data Corporation, June 10, 2009
- Standard & Poor's Securities Evaluations, Inc., June 10, 2009
- Sanford C. Bernstein & Co., LLC, June 9, 2009
- PIMCO ETF Trust, June 1, 2009
- Morgan Stanley and Citigroup Inc., May 12, 2009
- Grail Advisors ETF Trust, April 30, 2009
- FS Investment Corporation, April 20, 2009
- Lloyds Banking Group plc, April 20, 2009
- Legg Mason Investor Services, LLC, April 7, 2009
- Index IQ ETF Trust, March 25, 2009
- Omgeo, March 19, 2009
- Financial Industry Regulatory Authority, Inc., March 17, 2009
- The Depository Trust & Clearing Corporation, March 13, 2009
- Shinhan Financial Group Co., Ltd., March 5, 2009
- The Royal Bank of Scotland Group plc and ABN AMRO Holding N.V., February 18, 2009
- WisdomTree Trust Dreyfus Emerging Currency Fund, January 7, 2009
- Boston Stock Exchange, December 23, 2008
- Banco Santander, S.A., December 22, 2008
- Direxion Shares ETF Trust, December 15, 2008
- ShareGift USA, December 3, 2008
- MS&Co. OTC Swap Transactions Referencing a Merger Arbitrage Index, December 1, 2008
- Securities Industry and Financial Markets Association, November 20, 2008
- PowerShares Actively Managed Exchange-Traded Fund Trust, November 14, 2008
- AirShares EU Carbon Allowances Fund and XShares Advisors LLC, November 10, 2008
- Banco Santander, S.A., November 7, 2008
- Direxion Shares ETF Trust, October 30, 2008
- BATS Exchange, Inc., October 23, 2008
- Lloyds TSB Group plc, October 21, 2008
- Royal Bank of Scotland Group plc and ABN AMRO Holding N.V., October 17, 2008
- Cash Tender Offer by International Business Machines Corporation for Ordinary Shares and ADSs of ILOG S.A., October 9, 2008
- Barclays Capital Inc., September 19, 2008
- Pershing LLC, September 10, 2008
- Petersen Energía Inversora, S.A., September 9, 2008
- Banco Santander, S.A., August 18, 2008
- SS&C Technologies, Inc., August 13, 2008
- MACRO Securities Depositor, LLC, July 1, 2008
- Republic of Uruguay, June 24, 2008
- Barclays PLC, June 16, 2008
- UBS AG, May 16, 2008
- WisdomTree Trust, May 9, 2008
- TIAA-CREF, May 2, 2008
- Rydex ETF Trust, April 24, 2008
- UBS AG, April 22, 2008
- Royal Bank of Scotland Group plc and ABN AMRO Holding N.V, April 21, 2008
- PowerShares Actively Managed ETF Trust, April 4, 2008
- Loews Corporation, March 27, 2008
- Bear Stearns Active ETF Trust, March 24, 2008
- JPMorgan Chase & Co., March 19, 2008
- Municipal Auction Rate Securities, March 14, 2008
- Omgeo LLC, March 12, 2008
- Reuters Group PLC and Thomson Reuters PLC, February 29, 2008
- Woodstock Financial Group, Inc., January 14, 2008
- Securities Industry and Financial Markets Association, January 10, 2008
- Bloomberg Tradebook LLC and Calyon Inc., December 31, 2007
- Toronto-Dominion Bank, December 21, 2007
- PT Media Nusantara Tbk, December 18, 2007
- SAP AG, December 5, 2007
- ADP TotalSource, Inc., December 4, 2007
- eEmployers Solutions, Inc., December 3, 2007
- LiquidityHub Limited, November 28, 2007
- Chicago Stock Exchange, Inc., November 15, 2007
- Woodstock Financial Group, Inc., November 7, 2007
- Rydex ETF Trust, October 31, 2007
- Class Relief for Real Estate Investment Trust Share Redemption Programs, October 22, 2007
- Deutsche Bank AG (Exchange-traded Notes), October 12, 2007
- REITPlus, Inc., October 9, 2007
- ASX Limted, August 13, 2007
- ABN AMRO Holding N.V., , August 7, 2007
- Barclays PLC, August 7, 2007
- Barclays PLC, August 2, 2007
- NASD, July 27, 2007
- Nasdaq Stock Market LLC/The Portal® Market, July 31, 2007
- Banco Santander Central Hispano, S.A., July 23, 2007
- Fortis SA/NV and Fortis NV, July 23, 2007
- Royal Bank of Scotland Group plc, July 23, 2007
- Royal Bank of Scotland Group plc, July 20, 2007
- SunGard Institutional Brokerage, Inc., July 3, 2007
- American Stock Exchange LLC, July 2, 2007
- Securities Industry and Financial Markets Association, July 2, 2007
- Ameristock ETF Trust, June 29, 2007
- Combination Exchange-traded Funds, June 27, 2007
- Banco Bilbao Vizcaya Argentaria, S.A, June 25, 2007
- Hallmark Capital Corporation, June 11, 2007
- UBS Financial Services Inc., May 24, 2007
- Fixed Income Clearing Corporation, May 23, 2007
- Japan Credit Rating Agency, Ltd., May 23, 2007
- Grupo Aeropotuario del Sureste, May 9, 2007
- Wachovia Securities, April 30, 2007
- Barclays/ABN AMRO, April 24, 2007
- Capital Institutional Services, Inc., April 13, 2007
- Cole Credit Property Trust II, April 11, 2007
- Class Relief for Fixed Income Exchange-Traded Funds, April 9, 2007
- CANTV, April 6, 2007
- Cleary Gottlieb Steen & Hamilton LLP, April 4, 2007
- Allianz SE, March 27, 2007
- Allianz SE, March 23, 2007
- STATS ChipPAC Ltd., March 15, 2007
- HealthShares Composite Exchange-Traded Fund, March 8, 2007
- Sulzer AG, March 2, 2007
- Asia Satellite Communications Holdings Limited, March 1, 2007
- Chicago Board Options Exchange, Inc., February 23, 2007
- Exemptive Relief for Purchases Pursuant to Statutory Puts in Japanese Tender Offers, February 20, 2007
- Suzlon Energy Limited, February 9, 2007
- UnumProvident Corporation, Inc., February 8, 2007
- NYSE Arca, Inc., January 31, 2007
- FSC Securities Corporation, January 30, 2007
- ProSiebenSat.1 Media AG, January 30, 2007
- Nippon Katan, January 26, 2007
- ProShares Trust, January 24, 2007
- Philadelphia Stock Exchange, Inc., January 23, 2007
- Areva S.A., January 22, 2007
- HealthShares Emerging Cancer Exchange-Traded Fund and HealthShares Cardio Devices Exchange-Traded Fund, January 22, 2007
- Hurriyet Invest, January 22, 2007
- Goldman, Sachs & Co., January 17, 2007
- Pfleiderer AG, January 12, 2007
- Securities Industry and Financial Markets Association, December 29, 2006
- iShares Lehman Short Treasury Bond Fund, iShares Lehman 3-7 Year Treasury Bond Fund, iShares Lehman 10-20 Year Treasury Bond Fund, iShares Lehman 1-3 Year Credit Bond Fund, iShares Lehman Intermediate Credit Bond Fund, iShares Lehman Credit Bond Fund, iShares Lehman Intermediate Government/Credit Bond Fund, iShares Lehman Government/Credit Bond Fund and iShares Lehman MBS Fixed-Rate Bond Fund, December 22, 2006
- MACRO Securities Depositor, LLC, December 22, 2006
- CenterPoint Energy, December 21, 2006
- Heat Beteiligungs III GmbH, December 20, 2006
- Gallaher Group plc, December 15, 2006
- Omgeo, LLC, December 14, 2006
- NYSE Arca, Inc., December 8, 2006
- International Securities Exchange, LLC, December 7, 2006
- Companhia Sidenúrgica Nacional, December 1, 2006
- TD Ameritrade, Inc., November 30, 2006
- UCB SA, November 29, 2006
- National Stock Exchange, November 28, 2006
- Nasdaq Stock Market, Inc., November 20, 2006
- Tokyo Stock Exchange, Inc., November 20, 2006
- Philadelphia Stock Exchange, Inc., November 9, 2006
- Boston Stock Exchange, November 8, 2006
- Country Business, Inc., November 8, 2006
- MEIF II, November 3, 2006
- EIG Mutual Holding Company, October 25, 2006
- Class Relief for Exchange Traded Index Funds, October 24, 2006
- National Stock Exchange, October 13, 2006
- American Stock Exchange LLC, October 12, 2006
- WisdomTree Trust, October 12, 2006
- Barrick Gold Corporation, October 10, 2006
- Telstra Corporation Limited, October 5, 2006
- Gondola Holdings plc, October 2, 2006
- TPO Investments AS, September 18, 2006
- Doughty Hanson & Co Investments L.P. Incorporated, September 12, 2006
- Hines Real Estate Investment Trust, Inc., September 7, 2006
- NNN Healthcare/Office REIT, Inc., August 24, 2006
- International Securities Exchange, Inc. , August 18, 2006
- Wachovia Securities, August 15, 2006
- NYSE Regulation, Inc., August 1, 2006
- NASDAQ Stock Market LLC, August 1, 2006
- Securities Industry Association, July 31, 2006
- National Association of Securities Dealers, Inc., July 28, 2006
- iPath Securities — Exchange-Traded Notes, July 27, 2006
- Chicago Stock Exchange, Inc., July 20, 2006
- UBS AG, July 13, 2006
- Securities Industry Association, July 11, 2006
- PMI Group, Inc., July 6, 2006
- John W. Loofbourrow Associates, Inc., June 29, 2006
- Bloomberg Tradebook LLC, June 28, 2006
- BATS Trading, Inc., June 28, 2006
- OnTrade, Inc., June 28, 2006
- Direct Edge ECN, June 28, 2006
- Track ECN, June 28, 2006
- Welton Street Investments, LLC, June 27, 2006
- NASD, Inc., June 26, 2006
- Dinosaur Securities, LLC, June 23, 2006
- Associated British Ports Holdings plc, June 22, 2006
- Mittal Steel Company N.V, June 22, 2006
- Professional Project Services, Inc., June 22, 2006
- CurrencyShares British Pound Sterling Trust, CurrencyShares Australian Dollar Trust, CurrencyShares Canadian Dollar Trust, CurrencyShares Mexican Peso Trust, CurrencyShares Swedish Krona Trust, and CurrencyShares Swiss Franc Trust, June 21, 2006
- ProShares Trust, June 20, 2006
- Instinet Group, LLC, June 15, 2006
- WisdomTree Trust, June 15, 2006
- Associated British Ports Holdings plc, June 8, 2006
- Securities Industry Association, June 8, 2006
- iPath Securities — Index-Linked Securities, May 30, 2006
- AstraZeneca PLC, May 23, 2006
- M Financial Holdings, Inc., May 8, 2006
- BATS Trading, Inc., May 8, 2006
- Eurex, May 3, 2006
- Investor AB, April 6, 2006
- Scottish Power plc, April 3, 2006
- Grupo Ferrovial, SA, March 23, 2006
- Chicago Stock Exchange, Inc., March 16, 2006
- Philadelphia Stock Exchange, Inc., March 8, 2006
- Direct Edge ECN LLC, March 3, 2006
- Gas Natural SDG, S.A., March 2, 2006
- TriNet Group, Inc., February 17, 2006
- BATS Trading, Inc., February 17, 2006
- Dividend Capital Total Realty Trust Inc., January 31, 2006
- DB Commodity Index Tracking Fund and DB Commodity Services LLC, January 19, 2006
- Fresenius Medical Care AG, January 13, 2006
- OnTrade, Inc./NexTrade ECN: Withdrawal of No-Action Position, January 11, 2006
- OnTrade, Inc., January 11, 2006
- United Development Funding III, LP, January 11, 2006
- Offer by Crucell N.V. for Shares of Berna Biotech A.G., January 5, 2006
- CommandTRADE, LP, December 28, 2005
- New York Stock Exchange, Inc. and NASD Regulation, Inc., December 16, 2005
- streetTRACKS Gold Trust®, December 12, 2005
- iShares COMEX Gold Trust, December 12, 2005
- Euro Currency Trust, December 5, 2005
- WEBS Index Series, November 22, 2005
- streetTRACKS Series Trust, November 22, 2005
- Select Sector SPDRs, November 22, 2005
- iShares, Inc. MSCI Index Funds, November 22, 2005
- Foreign Fund, Inc., November 22, 2005
- Fresco Index Shares Funds, November 22, 2005
- Securities Industry Association, November 21, 2005
- Gas Natural SDG,, November 18, 2005
- Bloomberg Tradebook LLC, November 17, 2005
- Spark Infrastructure Group, November 8, 2005
- Old Mutual PLC for Försäkringsaktiebolaget Skandia, October 26, 2005
- PowerShares Lux Nanotech Portfolio, October 25, 2005
- Macquarie Airports Copenhagen ApS for Kobenhavns Lufthavne A/S, October 24, 2005
- Track ECN, October 21, 2005
- Inet ATS, Inc., October 21, 2005
- Direct Edge ECN LLC Purchase of ATTAIN ECN, October 21, 2005
- Domestic Securities, Inc./ATTAIN ECN, October 21, 2005
- TEOCO Corporation, October 20, 2005
- Pacific Exchange, Inc., October 13, 2005
- Key Hospitality Acquisition Corporation, October 12, 2005
- Profit Eagle Limited, October 11, 2005
- Attain System, October 7, 2005
- OnTrade, Inc., October 7, 2005
- The State of Oregon, October 4, 2005
- NASD, Inc., September 30, 2005
- Macquarie Media Holdings Limited and Macquarie Media Trust, September 27, 2005
- Axel Springer AG, September 12, 2005
- Chicago Stock Exchange, Inc., August 23, 2005
- National Stock Exchange, August 23, 2005
- Skadden, Arps, Slate, Meagher & Flom (UK) LLP, August 5, 2005
- iShares, August 4, 2005
- J.P. Morgan Securities Inc., August 4, 2005
- Compagnie de Saint-Gobain, July 29, 2005
- Eurex, July 27, 2005
- Securities Industry Association, July 18, 2005
- Chicago Stock Exchange, Inc., July 1, 2005
- Pacific Exchange, Inc., June 29, 2005
- National Stock Exchange, June 28, 2005
- NASD Regulation, Inc., re: Net Capital Relief Related to Certain Transactions in the Securities of Gluv Corp., June 16, 2005
- D.A. Davidson & Co., June 10, 2005
- William Blair & Company L.L.C., June 10, 2005
- Wolff Juall Investments, LLC, May 17, 2005
- R & H Management, L.L.C., April 25, 2005
- ITG, Inc., April 22, 2005
- Morgan Keegan & Co., Inc., April 20, 2005
- Sanford C. Bernstein & Co., LLC, April 18, 2005
- Securities Industry Association, April 15, 2005
- National Futures Association, April 11, 2005
- Barclays Bank PLC for Absa Group Limited, April 4, 2005
- Boston Stock Exchange, Inc., April 1, 2005
- Reliance Trust Company, March 29, 2005
- Freshfields Bruckhaus Deringer, March 17, 2005
- Vanguard Emerging Markets Stock Index Fund, Vanguard European Stock Index Fund and Vanguard Pacific Stock Index Fund, March 9, 2005
- A.M. Best Company, Inc., March 3, 2005
- Average Price, Multiple Capacity Confirmations, March 3, 2005
- PowerShares WilderHill Clean Energy Portfolio, March 2, 2005
- New York Stock Exchange, Inc., February 11, 2005
- Pacific Exchange, Inc., February 10, 2005
- Securities Industry Association, February 10, 2005
- iShares COMEX Gold Trust®, January 27, 2005
- Nasdaq Stock Market, Inc., January 26, 2005
- BRUT System, January 6, 2005
- Trading System Operated by OnTrade, Inc., January 6, 2005
- Inet ECN, January 6, 2005
- Tradebook System, January 6, 2005
- Attain System, January 6, 2005
- Track System, January 6, 2005
- Sullivan & Cromwell LLP, December 15, 2005
- Schiff Hardin LLP, January 3, 2005
- Securities Industry Association, January 3, 2005
- United Technologies Corporation for Kidde plc, December 15, 2004
- Dilworth Capital Management, LLC, December 9, 2004
- streetTRACKS Gold Trust®, November 17, 2004
- The Equitable Life Assurance Society of the United States, October 20, 2004
- Lend Lease Corporation Limited, October 15, 2004
- Paladin Realty Income Properties, Inc., October 14, 2004
- TECO Energy, Inc., October 8, 2004
- iShares FTSE/Xinhua China 25 Index Fund, October 8, 2004
- Chicago Stock Exchange, Inc., October 6, 2004
- Hughes Supply, Inc., October 4, 2004
- Boston Stock Exchange, Inc., October 1, 2004
- Borsa Italiana S.p.A., September 24, 2004
- NASD Regulation, Inc., September 10, 2004
- Banco Santander Central Hispano, S.A., September 10, 2004
- Orange Hospitality, Inc., September 9, 2004
- Wells Fargo Bank, N.A., July 29, 2004
- Chicago Board Options Exchange, Inc., July 12, 2004
- International Securities Exchange, Inc., June 24, 2004
- Texas Treasury Safekeeping Trust Company, June 16, 2004
- Instinet Group, LLC, June 8, 2004
- GmbH for P & I Personal & Informatik Aktiengesellscaft, June 24, 2004
- UCB S.A., May 19, 2004
- CNL Retirement Properties, Inc., May 19, 2004
- San Diego Chapter of the National Association of Investors Corporation, May 14, 2004
- SABMiller PLC, May 10, 2004
- Anheuser-Busch Companies, Inc., May 7, 2004
- Associated Grocers of Maine, Inc., May 6, 2004
- The Pacific Exchange, Inc., April 30, 2004
- Songbird Acquisition Limited, April 22, 2004
- OnTrade, Inc., April 2, 2004
- Inet ECN, April 2, 2004
- BRUT System, April 1, 2004
- Track ECN, April 1, 2004
- Attain Systems, April 1, 2004
- NexTrade, Inc., April 1, 2004
- Bloomberg Tradebook, April 1, 2004
- BLB Investors, L.L.C., March 31, 2004
- Popular High Grade Fixed-Income Fund, Inc., March 31, 2004
- National Futures Association, March 22, 2004
- Harborside Securities, L.L.C., March 16, 2004
- CNL Income Properties, Inc., March 11, 2004
- Securities Industry Association, February 12, 2004
- Canary Wharf Group plc, February 9, 2004
- Boston Stock Exchange, Inc., February 4, 2004
- Banco Bilbao Vizcaya Argentaria, S.A. for Series B Shares and American Depository Shares of Grupo Financiero BBVA Bancomer, S.A. de C.V., February 2, 2004
- Republic of Panama, January 16, 2004
- Federative Republic of Brazil, January 12, 2004
- Wells Real Estate Investment Trust II, Inc., December 9, 2003
- EDX London Limited and OM London Exchange Limited, October 29, 2003
- ING Senior Income Fund, October 9, 2003
- Investacorp Group, Inc., September 26, 2003
- Nasdaq Stock Market, Inc., September 15, 2003
- Loffa Interactive Corp., Inc., September 12, 2003
- Banyu Pharmaceutical Co. Ltd., September 11, 2003
- Inland Western Retail Real Estate Trust, Inc., August 25, 2003
- Lincoln National Life Insurance Company, August 22, 2003
- Clark Street Capital, Inc., August 20, 2003
- Goldman, Sachs & Co., August 14, 2003
- Rizzoli Corriere della Sera Medical Group S.p.A. for Fila Holding S.p.A.., July 28, 2003
- Edward D. Jones & Co., LP, August 1, 2003
- Trade Web, Jul 22, 2003
- Recording Certain Broker-Dealer Expenses and Liabilities, July 11, 2003
- Popular Total Return Fund, Inc., July 1, 2003
- Silver Young Trading LLC, June 25, 2003
- Twins Acquisition, Inc. Offer for IDS Group plc, June 25, 2003
- The Operating Committee of the Options Linkage Authority, May 30, 2003
- Serono France Holding S.A., May 14, 2003
- Portfolio System for Institutional Trading, April 23, 2003
- Allianz AG, April 10, 2003
- Chicago Board Options Exchange, March 31, 2003
- Bion Environmental Technologies, Inc., March 18, 2003
- Large Order Utility System, March 12, 2003
- Edward Mahaffy, March 6, 2003
- Notice Registration Requirements, March 5, 2002
- Vodafone Group Plc, March 3, 2003
- Dominion Bond Rating Service Limited, February 24, 2003
- UBS AG, London Branch and J.P. Morgan Securities Limited, February 21, 2003
- Vie Institutional Services, February 12, 2003
- Banyu Pharmaceutical Co. Ltd., January 9, 2003
- Offer by CIBER (UK) for ECsoft Group plc, January 8, 2003
- Republic of Colombia, December 2, 2002
- Tokyo Stock Exchange, Inc., November 15, 2002
- Nasdaq Stock Market, Inc., November 13, 2002
- The Island ECN, November 7, 2002
- Treasury FITR Exchange Traded Funds, November 1, 2002
- Instinet Corporation, November 1, 2002
- Fresco Index Shares Funds, October 21, 2002
- ING Senior Income Fund, October 17, 2002
- Bank of Ireland Abby National, October 16, 2002
- Pepsi Bottling Group, Inc., Bottling Group LLC and PBG Grupo Embotellador Hispano-Mexicano S.L., October 14, 2002
- Bank of Ireland Abby National, October 8, 2002
- Serono S.A. Offer for All Outstanding Ordinary Shares, ADSs, OCEANEs and Warrants of Genset, September 12, 2002
- Koninklijke Ahold N.V.'s Tender Offer for Shares and ADSs of Santa Isabel S.A., September 10, 2002
- Popular High Grade Fixed-Income Fund, September 10, 2002
- DB Sechste Vermögensverwaltungsgesellschaft mbH for Stinnes AG, August 29, 2002
- Securities Industry Association and Futures Industry Association, August 20, 2002
- Headway Corporate Staff Administration, August 14, 2002
- Scripophily.com, August 14, 2002
- Market XT, August 8, 2002
- Saipem SpA, July 29, 2002
- National Association of Securities Dealers Order Audit Trail Rules 6950 through 6957, July 25, 2002
- Nasdaq Stock Market, Inc., July 23, 2002
- iShares Trust ("Trust"), iShares 1-3 Year Treasury Index Fund, iShares 7-10 Year Treasury Index Fund, iShares 20+ Year Treasury Index Fund, iShares Treasury Index Fund, iShares Government/Credit Index Fund, iShares Lehman Corporate Bond Fund, and iShares Goldman Sachs InvesTop Corporate Bond Fund, July 15, 2002
- American Stock Exchange, July 9, 2002
- Kentucky Public Employees' Deferred Compensation Authority, July 8, 2002
- Votorantim Celulose e Papel S.A., June 18, 2002
- Kingfisher Plc Offer for Castorama Dubois Investissements SCA, June 4, 2002
- SelectNet and SuperMontage, June 4, 2002
- Swiss American Securities Inc. and Streetline, Inc., May 28, 2002
- RAES System, May 16, 2002
- Herbruck, Alder & Co., May 3, 2002
- AUTOM System, April 15, 2002
- Maine Securities Regulator, April 9, 2002
- BRUT System, April 1, 2002
- GlobeNet Trading System, March 29, 2002
- Instinet Real-Time Trading Services, March 29, 2002
- Island System ECN, March 29, 2002
- MarketXT, March 29, 2002
- REDI System, March 29, 2002
- Track ECN, March 29, 2002
- RWE Aktiengesellschaft, March 22, 2002
- Biotech Boxes, March 19, 2002
- Century Business Services, Inc. and CBIZ Financial Solutions, Inc., March 1, 2002
- Telex-Chile, S.A., March 5, 2002
- BRUT ECN, LLC, February 1, 2002
- OneShare.com, January 16, 2002
- Digital Assurance Certification L.L.C., September 21, 2001
- NASD Small Firm Advisory Board, September 21, 2001
- Nasdaq Stock Market, Inc., September 21, 2001
- Securities Industry Association, September 21, 2001
- Exemptive Relief for Exchange Traded Index Funds, August 17, 2001
- Acqua Wellington North America Equities Fund, Ltd., July 11, 2001
- First Union Securities, Inc., June 22, 2001
- NASD Small Firms Advisory Board, June 22, 2001
- New York Stock Exchange, Inc., June 22, 2001
- Nasdaq Stock Market, Inc., June 22, 2001
- Market Systems, Inc., June 22, 2001
- 1st Global, Inc., May 7, 2001
- Securities Industry Association, April 12, 2001
- Securities Industry Association, March 12, 2001
- Nasdaq Stock Market, Inc., March 12, 2001
- Dominion Resources, Inc., March 7, 2000 (A copy of the Dominion Resources letters from 1985 is posted by Westlaw with permission of Thompson Reuters.)
- London International Financial Futures and Options Exchange ("LIFFE"), March 3, 2000
- Regulation M — Sovereign Bond Exemption, January 12, 2000
- Tokyo Stock Exchange, July 27, 1999
- Osaka Securities Exchange, July 23, 1999
- MONEP SA, October 26, 1998
- NASD Regulation, Inc., December 1, 1998
- Mercato Italiano dei Derivati - IDEM Equity and Index Options, September 1, 1998
- Attkisson, Carter, & Akers, June 23, 1998
- Cleary, Gottlieb, Steen and Hamilton, March 24, 1997
- Charles Schwab & Co., Inc., November 27, 1996
- Société de Compensation des Marchés Conditionnels, June 17, 1996
- London International Financial Futures and Options Exchange ("LIFFE"), March 6, 1996
- Bear, Stearns & Co. Inc.; CS First Boston corporation; CSFP Capital, Inc.; Goldman, Sachs & Co.; Lehman Brothers Inc.; Morgan Stanley & Co. Incorporated; and Salomon Brothers Inc, January 30, 1996
- Hang Seng Index Options, September 26, 1995
- NASD, Inc., December 20, 1993
- Chubb Securities Corporation November 24, 1993
- Securities Industry Association, September 20, 1993; incoming letter
- London International Financial Futures Exchange and London Traded Options Market, May 1, 1992
- London Traded Options Market, September 4, 1990
Interpretive Letters
Associated Persons of Broker-Dealers (including Registration, Bars, Statutory Disqualification, and Rule 19h-1)
- Financial Industry Regulatory Authority, Inc., March 17, 2009
Broker-Dealer Customer Protection Rule - Rule 15c3-3
- Charles Schwab & Co., Inc., February 3, 2012
Exchange Member Trading – Section 11(a)
- Philadelphia Stock Exchange, Inc., November 9, 2006
- Global Research Analyst Settlement, November 2, 2004
- American Stock Exchange, LLC, October 20, 2004
- Boston Stock Exchange, Inc., October 20, 2004
- Chicago Board Options Exchange, Inc., October 20, 2004
- International Securities Exchange, LLC, October 20, 2004
- Pacific Exchange, Inc., October 20, 2004
- Philadelphia Stock Exchange, Inc., October 20, 2004
- American Stock Exchange, LLC, June 15, 2004
- Boston Stock Exchange, Inc., June 15, 2004
- Chicago Board Options Exchange, Inc., June 15, 2004
- International Stock Exchange, LLC, June 15, 2004
- Pacific Exchange, Inc., June 15, 2004
- Philadelphia Stock Exchange, Inc., June 15, 2004
Financial Accounting Standards No. 150
- Additional Guidance for Broker-Dealers on FAS 150 (Interpretive Letter from the Office of Broker-Dealers, September 7, 2004)
Multiple Section Relief (e.g. exchange traded funds and other basket products)
- WisdomTree Emerging Markets Corporate Bond Fund, April 16, 2012
- PIMCO Total Return Exchange-Traded Fund, March 1, 2012
- Claymore Exchange-Traded Fund Trust, December 16, 2011
- AdvisorShares Trust, December 16, 2011
- iShares Trust Equity-Index Exchange Traded Fund, November 3, 2011
- WisdomTree Global Real Return Fund, August 29, 2011
- WisdomTree Asia Local Debt Fund, August 16, 2011
- WisdomTree Managed Futures Strategy Fund, August 16, 2011
- Claymore Exchange-Traded Fund Trust, May 24, 2011
- AdvisorShares Active Bear ETF, January 19, 2011
- AdvisorShares Trust Actively Managed ETF, December 16, 2010
- PIMCO ETF Trust - Actively Managed ETF, September 22, 2010
- WisdomTree Trust Dreyfus Commodity Currency Fund an Actively Managed ETF, September 2, 2010
- iShares Trust Equity-Index Exchange Traded Funds, August 17, 2010
- WisdomTree Trust Emerging Markets Local Debt Fund an Actively Managed ETF, August 6, 2010
- AdvisorShares Mars Hill Global Relative Value Actively Managed ETF, July 2, 2010
- AdvisorShares Trust Actively-Managed ETF, WCM/BNY Mellon Focused Growth ADR, June 18, 2010
- WisdomTree Trust Real Return Actively Managed ETF, May 27, 2010
- U.S. One Trust Actively-Managed ETF of ETFs, May 4, 2010
- Grail Advisors ETF Trust Actively Managed Fixed Income ETF, January 27, 2010
- WisdomTree Trust Index-Based ETF of ETFs, December 23, 2009
- iShares Diversified Alternatives Trust Actively-Managed Commodity-Based Investment Vehicle, November 12, 2009
- PIMCO ETF Trust Actively Managed Fixed Income ETF, November 10, 2009
- AdvisorShares Trust Actively-Managed ETF of ETFs and Exchange Traded Products, September 14, 2009
- PIMCO ETF Trust, August 20, 2009
- PIMCO ETF Trust, June 1, 2009
- Index IQ ETF Trust, March 25, 2009
Municipal Securities
- www.DisclosureUSA.org - Texas MAC's Central Post Office, Interpretive Letter from the Office of Municipal Securities, October 3, 2007
- www.DisclosureUSA.org - Texas MAC's Central Post Office, Interpretive Letter from the Office of Municipal Securities, September 7, 2004
Rule 10b-10, Confirmations
- Omgeo LLC, November 19, 2010
Rule 10b-18, Issuer Repurchases
- NYSE, LLC and NYSE Amex LLC, February 3, 2010
Securities - Definition - Government Securities
- National Credit Union Administration, September 24, 2010
Securities - Definition - Specialized Products
- UBS AG, New York Branch, June 8, 2006
Surveillance-Sharing Agreements
- Intermarket Surveillance Group, June 3, 1994
Exemptive Orders
Last Reviewed or Updated: April 15, 2024