[13700]
July 5, 2001
TO: ADVERTISING COMPLIANCE ADVISORY COMMITTEE No. 9-01
EQUITY MARKETS ADVISORY COMMITTEE No. 22-01
SEC RULES COMMITTEE No. 52-01
RE: ICI COMMENT LETTER ON NASDR REQUEST FOR COMMENT ON MODERNIZING
NASD RULES
The Institute recently filed the attached comment letter with NASD Regulation, Inc. in
response to its request for comment concerning steps that can be taken to modernize NASD
rules.1 The letter is substantially similar to the draft letter circulated previously.2
The Institute’s letter updates and supplements comments filed in 1999 in response to a
similar NASDR request for comment, and makes general recommendations relating to
differentiation between institutional and retail customers, prospectus disclosure, and the NASD
rulemaking process. In addition, the letter discusses the status of previously recommended
changes in the areas of: advertising and sales literature; confirmations; forwarding proxy
materials; the corporate financing rule; selling concessions; and cash compensation.
Kathy D. Ireland
Associate Counsel
Attachment
Attachment (in .pdf format)
1 See Memorandum to Advertising Compliance Advisory Committee No. 5-01, Equity Markets Advisory Committee
No. 16-01 and SEC Rules Committee No. 41-01, dated May 29, 2001.
2 See Memorandum to Advertising Compliance Advisory Committee No. 6-01, Equity Markets Advisory Committee
No. 20-01 and SEC Rules Committee No. 48-01, dated June 21, 2001.