* See Memorandum to Advertising Compliance Subcommittee No. 25-98 and SEC Rules Committee No. 56-98, dated
June 12, 1998.
[10080]
June 29, 1998
TO: ADVERTISING COMPLIANCE SUBCOMMITTEE No. 30-98
SEC RULES COMMITTEE No. 64-98
RE: INSTITUTE COMMENT LETTER ON NASD PROPOSAL TO AMEND
RECORD-KEEPING REQUIREMENTS
______________________________________________________________________________
The Institute recently filed with the Securities and Exchange Commission the attached comment
letter on a proposal to amend National Association of Securities Dealers, Inc. Rule 3110 to exclude from
certain record-keeping requirements accounts that are limited to mutual fund shares that are not
recommended by the NASD member or its associated persons.* The comment letter strongly supports
the proposal, but recommends that it be revised to make clear that accounts that are limited to
transactions in money market funds (including where such funds are recommended to the customer)
remain exempt from these record-keeping requirements.
Joseph P. Savage
Assistant Counsel
Attachment