Memo #
9289
INSTITUTE COMMENT LETTER ON PROPOSED NASD POLICY RELATING TO THE ELECTRONIC DELIVERY OF INFORMATION BETWEEN MEMBERS AND THEIR CUSTOMERS
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1 See Memorandum to Advertising Subcommittee No. 31-97 and SEC Rules Committee No. 89-97 dated September 15,
1997.
2 See Securities Act Release No. 7233 (Oct. 6, 1995), 60 Fed. Reg. 53458 (Oct. 13, 1995); Securities Exchange Act
Release No. 37182 (May 9, 1997), 61 Fed. Reg. 24644 (May 15, 1996).
[9289]
September 29, 1997
TO: ADVERTISING SUBCOMMITTEE No. 34-97
SEC RULES COMMITTEE No. 95-97
RE: INSTITUTE COMMENT LETTER ON PROPOSED NASD POLICY RELATING
TO THE ELECTRONIC DELIVERY OF INFORMATION BETWEEN MEMBERS
AND THEIR CUSTOMERS
______________________________________________________________________________
As we previously reported, the National Association of Securities Dealers, Inc. recently
filed with the Securities and Exchange Commission a proposed Notice to Members setting forth
the NASDs policy relating to the electronic delivery of information between NASD members
and their customers.1 The NASDs policy is based upon the SECs guidelines that were
published in October 1995 and May 1996 and that establish a framework under which broker-
dealers and others may use electronic media as alternatives to paper-based media to satisfy
delivery obligations under federal securities laws.2 The Notice states that use of electronic
media is permitted, provided that members comply with the standards contained in the SEC
releases. The Notice also contains a list of current NASD rules that require or permit
communications between members and their customers for which electronic delivery may be
used in accordance with the SEC releases. The comment letter generally supports this
approach, but recommends that certain other NASD rules be added to the list contained in the
Notice.
Comments on this proposal must be filed with the SEC by Thursday, October 2, 1997.
If you have any comments on this draft, please either call (202/326-5819) or e-mail
(savage@ici.org) me by the close of business, Wednesday, October 1, 1997.
Joseph P. Savage
Assistant Counsel
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