Comments on Interpretive Rule: Commission Guidance Regarding Client Commission Practices Under Section 28(e) of the Securities Exchange Act of 1934

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Date Received
Date Letter Type Commenter Name
Meeting with SEC Officials Memorandum from the Division of Market Regulation regarding a June 6, 2006 meeting with representatives of Sanford C. Bernstein
Meeting with SEC Officials Memorandum from the Office of Commissioner Atkins regarding a June 5, 2006 meeting with representatives from Merrill Lynch
Public Comment Charles E. Schumer, United States Senator, and John E. Sununu, United States Senator
Public Comment Lee A. Pickard, Esq. and William D. Edick, Esq. Pickard and Djinis LLP, Counsel to The Alliance In Support Of Independent Research
Public Comment Thomas A. Renyi, Chairman and Chief Executive Officer, The Bank of New York
Meeting with SEC Officials Memorandum from the Division of Market Regulation regarding a May 1, 2006 meeting between members of the Division of Market Regulation and John Meserve of Westminster Research Associates, a BNY Securities Group Company
Meeting with SEC Officials Memorandum from the Division of Market Regulation regarding an April 5, 2006 meeting between members of the Division of Market Regulation and members of the Alliance in Support of Independent Research
Meeting with SEC Officials Memorandum from the Division of Market Regulation regarding an April 27, 2006 meeting with representatives from Merrill Lynch & Co.
Public Comment Thomas N. McManus, Managing Director and Counsel, Morgan Stanley, New York, New York
Public Comment Peter E. Bulger, Chief Operating Officer, C.L. King & Associates, Inc., Albany, New York
Meeting with SEC Officials Memorandum from the Office of the Chairman regarding an April 5, 2006 meeting with representatives of the Alliance in Support of Independent Research.
Public Comment William T. George, Blue Sky Research Services, Encino, California
Public Comment David W. Miller, Vice-President and Assistant General Counsel, J.P. Morgan Securities Inc.
Public Comment Steve Goswell, Chair; Genevy Dimitrion, Vice Chair; Gary Probert, Vice Chair; ISITC (North America)
Public Comment Ann L. Combs, Assistant Secretary, Employee Benefits Security Administration, U.S. Department of Labor
Public Comment Neil Radey, Managing Director and General Counsel Americas, Credit Suisse Securities (USA) LLC, New York, New York
Meeting with SEC Officials Memorandum from the Division of Market Regulation regarding a March 2, 2006 meeting with representatives from JP Morgan Securities Inc.
Meeting with SEC Officials Memorandum from the Division of Market Regulation regarding a January 17, 2006 meeting with representatives from Goldman Sachs & Co.
Meeting with SEC Officials Memorandum from the Division of Market Regulation regarding a January 6, 2006 meeting with representatives from the Bank of New York, Morgan Lewis & Bockius LLP, ING Investment Management, and Mayer, Brown, Rowe & Maw LLP
Meeting with SEC Officials Memorandum from the Division of Market Regulation regarding a December 19, 2005 meeting with representatives of the Investment Adviser Association and T. Rowe Price
Meeting with SEC Officials Memorandum from the Division of Market Regulation regarding a January 6, 2006 meeting with representatives of The Bank of New York
Meeting with SEC Officials Memorandum from the Division of Market Regulation regarding a November 22, 2005 meeting with representatives from Instinet, LLC, and Kirkpatrick & Lockhart Nicholson Graham LLP
Public Comment Phillip K. Lynch, Chief Executive Officer, Reuters America LLC
Public Comment Julian Rainero, Bingham McCutchen LLP, on behalf of Frank Russell Securities, Inc.
Public Comment Tamar Frankel, Professor of Law, Boston University
Public Comment Eric D. Roiter, Senior Vice President and General Counsel, Fidelity Management & Research Company
Public Comment Vandham Securities Corp.
Public Comment Dixie L. Johnson, Committee on Federal Regulation of Securities, Business Law Section, American Bar Association
Public Comment Jeffrey T. Letzler, Deputy General Counsel, Instinet, LLC, New York, New York
Public Comment Heidi Stam, General Counsel, The Vanguard Group, Inc., Valley Forge, Pennsylvania

Last Reviewed or Updated: Dec. 18, 2025

File Number
S7-09-05
Release Number
34-52635
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