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NASD Offers Registration Guidance

Who Needs to Register?

By John M. Baker, Esq.

NASD Rules 1030 – 1042 provide general guidance on the appropriate functions of broker-dealers’ registered representatives, but it can at times be difficult to apply these rules to specific activities. The NASD has just posted a December 23, 1999, interpretive letter to Brokerage Administrators Corporation, setting out the registration requirements for a broad range of telephonic activities.

The requestor had submitted a chart outlining a number of activities and indicating whether, in its view, each activity requires Series 7 (General Securities Representative), Series 6 (Limited Representative – Investment Company and Variable Contracts Products), Series 11 (Assistant Representative – Order Processing), or no registration.

The NASD endorsed the majority of these conclusions, making corrections as it thought fit. The NASD in several cases was more liberal than the requester, particularly with regard to the one-way provision of information by an unregistered person.

Although the NASD letter unfortunately gives minimal explanation of its conclusions, it is still the most specific guidance available on NASD registration requirements for teleservicing activities.

The letter is available at

Brokerage Administrators Corporation’s request letter, which includes the chart, is available in PDF format at

Copyright 2000, John M. Baker, Esq., Stradley, Ronon, Stevens & Young, LLP, 1220 19th Street, N.W., Suite 700, Washington, DC 20036 – (202) 822-9611- Fax (202) 822-0140 This article was originally posted to the FundLaw List, To subscribe to FundLaw, send a blank e-mail to

Nothing herein is intended as legal or financial advice. The law is different in different jurisdictions, and the facts of a particular matter can change the application of the law. Please consult an attorney or your financial advisor before acting upon the information contained in this article.  

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