Select regulatory documents by category:
Bank Dealers, Dealers
Bank Dealers, Dealers, Municipal Advisors
All Comments to Notice 2021-12
1. Bond Dealers of America: Letter from Michael Decker, Senior Vice President, dated January 19, 2022
2. First River Advisory L.L.C.: Letter from Shelley J. Aronson dated January 18, 2022
3. National Association of Municipal Advisors: Letter from Susan Gaffney, Executive Director, dated January 19, 2022
4. Securities Industry and Financial Markets Association: Letter from Leslie M. Norwood, Managing Director and Associate General Counsel, and Matthew Roberts, Assistant Vice President, dated January 19, 2022
Approval of Fair Practice Rules
Rule D-11 is designed to eliminate the need to make specific reference to personnel of securities firms and bank dealers in each Board rule that applies both to the organization and its personnel.
The term “associated person” in rule D-11 has the same meaning as set forth in section 3(a)(18) and 3(a)(32) of the Act, except that clerical and ministerial personnel are excluded from the definition for purposes of the Board’s rules, unless otherwise specified. Although the statutory definitions of associated persons include individuals and organizations in a control relationship with the securities professional, the context of the fair practice rules indicates that such rules will ordinarily not apply to persons who are associated with securities firms and bank deal- ers solely by reason of a control relationship.
