Self-Regulatory Organizations: Financial Industry Regulatory Authority, Inc.; Order Approving Proposed Rule Change Relating to the Adoption of FINRA Rule 3220 (Influencing or Rewarding Employees of Others) and FINRA Rule 2070 (Transactions Involving FINRA Employees) in the Consolidated FINRA Rulebook, 57393-57395 [E8-23196]
Download as PDF
Federal Register / Vol. 73, No. 192 / Thursday, October 2, 2008 / Notices
post all comments on the Commission’s
Internet Web site (https://www.sec.gov/
rules/sro.shtml). Copies of the
submission, all subsequent
amendments, all written statements
with respect to the proposed rule
change that are filed with the
Commission, and all written
communications relating to the
proposed rule change between the
Commission and any person, other than
those that may be withheld from the
public in accordance with the
provisions of 5 U.S.C. 552, will be
available for inspection and copying in
the Commission’s Public Reference
Room, 100 F Street, NE., Washington,
DC 20549, on official business days
between the hours of 10 a.m. and 3 p.m.
Copies of such filing also will be
available for inspection and copying at
the principal office of FINRA. All
comments received will be posted
without change; the Commission does
not edit personal identifying
information from submissions. You
should submit only information that
you wish to make available publicly. All
submissions should refer to File
Number SR–FINRA–2008–047 and
should be submitted on or before
October 23, 2008.
Exchange Act of 1934 (‘‘Act’’)1 and Rule
19b–4 thereunder,2 a proposed rule
relating to the adoption of FINRA Rule
3220 (Influencing or Rewarding
Employees of Others) and FINRA Rule
2070 (Transactions Involving FINRA
Employees) in the new consolidated
FINRA rulebook (‘‘Consolidated FINRA
Rulebook’’).3 The proposed rule change
was published for comment in the
Federal Register on August 11, 2008.4
The Commission received one comment
letter in response to the proposed rule
change.5 This order approves the
proposed rule change.
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.12
Florence E. Harmon,
Acting Secretary.
[FR Doc. E8–23195 Filed 10–1–08; 8:45 am]
II. Description of the Proposed Rule
Change
As part of the process of developing
the Consolidated FINRA Rulebook,
FINRA proposed to transfer without
material change NASD Rules 3060
(Influencing or Rewarding Employees of
Others) and 3090 (Transactions
Involving Association and American
Stock Exchange Employees) into the
Consolidated FINRA Rulebook and to
delete the corresponding provisions in
Incorporated NYSE Rules 350, 350.10,
407(a), 407.10 and NYSE Rule
Interpretations 350/01 through 350/03.
The proposed rule change would
renumber NASD Rule 3060 as FINRA
Rule 3220 and NASD Rule 3090 as
FINRA Rule 2070 in the Consolidated
FINRA Rulebook, and would delete
NASD Rules 3060 and 3090 in their
entirety from the Transitional Rulebook.
BILLING CODE 8011–01–P
(A) Proposed FINRA Rule 3220
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–58660; File No. SR–FINRA–
2008–027]
Self-Regulatory Organizations:
Financial Industry Regulatory
Authority, Inc.; Order Approving
Proposed Rule Change Relating to the
Adoption of FINRA Rule 3220
(Influencing or Rewarding Employees
of Others) and FINRA Rule 2070
(Transactions Involving FINRA
Employees) in the Consolidated FINRA
Rulebook
mstockstill on PROD1PC66 with NOTICES
September 26, 2008.
I. Introduction
On July 18, 2008, the Financial
Industry Regulatory Authority, Inc.
(‘‘FINRA’’) (f/k/a National Association
of Securities Dealers, Inc. (‘‘NASD’’))
filed with the Securities and Exchange
Commission (‘‘Commission’’) pursuant
to Section 19(b)(1) of the Securities
12 17
CFR 200.30–3(a)(12).
VerDate Aug<31>2005
17:52 Oct 01, 2008
Jkt 217001
(1) Background
NASD Rule 3060 (Influencing or
Rewarding Employees of Others)
currently states that no member or
associated person shall give gifts or
gratuities to an agent or employee of
another person in excess of $100 per
year where the gift or gratuity is in
relation to the business of the employer
of the recipient. The rule, which
1 15
U.S.C. 78s(b)(1).
CFR 240.19b–4.
3 The current FINRA rulebook consists of two sets
of rules: (1) NASD Rules and (2) rules incorporated
from NYSE (‘‘Incorporated NYSE Rules’’) (together
referred to as the ‘‘Transitional Rulebook’’). The
Incorporated NYSE Rules (hereinafter, ‘‘NYSE
Rules’’) apply only to those members of FINRA that
are also members of the NYSE (‘‘Dual Members’’).
Dual Members also must comply with NASD Rules.
For more information about the rulebook
consolidation process, see FINRA Information
Notice, March 12, 2008 (Rulebook Consolidation
Process).
4 See Securities Exchange Act Release No. 34–
58308 (August 5, 2008); 73 FR 46664 (Aug. 11,
2008) (notice).
5 See letter from Amal Aly, Managing Director
and Associate General Counsel, Securities Industry
and Financial Markets Association, dated Sept. 2,
2008 (‘‘SIFMA letter’’).
2 17
PO 00000
Frm 00076
Fmt 4703
Sfmt 4703
57393
protects against improprieties that may
arise when members or their associated
persons give gifts or gratuities to
employees of a customer, has been in
effect in its current form since 1969,
with changes only to the dollar
amounts, rising from $25 to $50 to
$100.6 The rule requires each member to
maintain a separate record of all gifts or
gratuities. The rule also contains an
express exclusion for payments made
pursuant to bona fide, written
employment contracts.
NYSE Rule 350 (Compensation or
Gratuities to Employees of Others)
reaches similar conduct in prohibiting,
absent prior written consent of the
recipient’s employer, any member or
member organization from giving any
gratuity in excess of $100 per person per
year to any principal, officer, or
employee of another member or member
organization, financial institution, news
or financial information media, or nonmember broker or dealer in securities,
commodities or money instruments.7
NYSE Rule 350 has specific provisions
addressing compensation to operations
employees of members (e.g., NYSE Floor
personnel). In addition, NYSE Rule 350
requires that records of all such
gratuities and compensation be retained
for at least three years.
(2) Proposal
FINRA proposed to transfer NASD
Rule 3060 into the Consolidated FINRA
Rulebook without material change and
renumbered as FINRA Rule 3220. One
of the advantages of the existing
regulatory standard is the clarity of the
rule’s application—it prevents gifts in
excess of a fixed amount, currently
$100. Both the NASD and NYSE rules
have a $100 limitation on gifts.
FINRA believes that NASD Rule 3060
generally is well understood by
members. FINRA recently issued
additional guidance on NASD Rule 3060
in Notice to Members 06–69.8 Among
the issues addressed in that Notice was
the fact that NASD Rule 3060 does not
apply to gifts of de minimis value, or to
promotional items of nominal value
6 See NASD Notice to Members 93–8 (February
1993) (SEC Approval of Amendment Relating to the
Payment of Gratuities or Anything of Value by
Members to Others); see also Securities Exchange
Act Release No. 21074 (June 20, 1984), 49 FR 26330
(June 27, 1984) (SR–NASD–84–8) (approval order).
7 In addition, NYSE Rule 350(a)(1) prohibits any
member from employing or compensating any
person for services rendered except with the prior
consent of that person’s employer. FINRA proposed
to delete this provision, even though it does not
pertain to gifts, because a substantively identical
provision exists in NYSE Rule 346(b). FINRA
intends to review NYSE Rule 346(b) as part of a
later phase of the rulebook consolidation process.
8 See NASD Notice to Members 06–69 (December
2006) (Gifts and Gratuities).
E:\FR\FM\02OCN1.SGM
02OCN1
57394
Federal Register / Vol. 73, No. 192 / Thursday, October 2, 2008 / Notices
mstockstill on PROD1PC66 with NOTICES
displaying a firm’s logo. The Notice
stated that NASD Rule 3060 does not
prohibit customary Lucite tombstones,
plaques or other similar solely
decorative items commemorating a
business transaction or event. The
Notice also stated that gifts should be
valued at the higher of cost or market
value and tickets should be valued at
the higher of cost or face value. In
addition, FINRA staff has used its
interpretive authority to address
unintended consequences of the rule,
such as unreasonable limitations on
giving a bereavement or sympathy gift.9
FINRA proposed to eliminate the
provision in NYSE Rule 350 permitting
member firms to obtain prior written
consent of the recipient’s employer for
any gift over $100. FINRA believes that
the gift rule should establish a fixed
amount and does not see any business
need to justify giving gifts in amounts
greater than the limits specified in the
rule. FINRA also would delete the
provisions in NYSE Rule 350 and NYSE
Rule Interpretation 350/02 addressing
compensation to operations/Floor
employees of NYSE as they are not
relevant for FINRA.10 For similar
reasons, provisions in NYSE Rule
350.10 pertaining to employment of or
gratuities to personnel working the
Floor of other exchanges would be
deleted.11 Finally, FINRA would
eliminate the provisions of NYSE Rule
350 relating to record retention, as
NASD Rule 3060(c) addresses the same
issue. FINRA proposed to eliminate
NYSE Rule Interpretation 350/01, and
provisions in NYSE Rule 350.10
pertaining to gifts among close relatives,
because the concepts contained in both
are adequately addressed by proposed
FINRA Rule 3220 and existing guidance.
Lastly, FINRA would eliminate NYSE
Rule Interpretation 350/03 because
FINRA has proposed a separate rule that
9 See Interpretive Letter dated December 17, 2007
to Amal Aly, SIFMA from Gary L. Goldsholle,
FINRA, available at: https://www.finra.org/
RulesRegulation/PublicationsGuidance/
InterpretiveLetters/ConductRules/P037695.
10 NYSE Rule Interpretation 350/02 would be
deleted in its entirety. Note that NYSE Rule 350
also contains provisions that address gifts and
gratuities to employees of the NYSE. These
provisions are addressed in connection with
FINRA’s proposal to adopt FINRA Rule 2070. See
Section (B) under Item II.A.1. FINRA’s proposals
with respect to FINRA Rules 3220 and 2070 would,
in combination, delete NYSE Rule 350 in its
entirety.
11 NYSE Rule 350.10 also contains provisions that
address employment or compensation of NYSE
employees by members or member organizations.
These provisions are addressed in connection with
FINRA’s proposal to adopt FINRA Rule 2070. See
Section (B) under Item II.A.1. Because Proposed
FINRA Rules 3220 and 2070 would address the
substance of NYSE Rule 350.10, FINRA proposed to
delete NYSE Rule 350.10 in its entirety.
VerDate Aug<31>2005
17:52 Oct 01, 2008
Jkt 217001
addresses business entertainment.12
Any guidance provided under NASD
Rule 3060, including, without
limitation, notices to members and
interpretation letters, also would apply
to the proposed FINRA Rule 3220.13 The
Commission notes three interpretative
letters previously issued with respect to
NASD Rule 3060.14 The interpretative
letters include FINRA’s rule on
members providing business
entertainment.15
(B) Proposed FINRA Rule 2070
(1) Background
Both NASD and NYSE rules address
conflicts of interest involving FINRA
and NYSE employees.
NASD Rule 3090 addresses this issue
in three ways. First, NASD Rule 3090(a)
requires a member, when it has actual
notice that an NASD employee has a
financial interest or controls trading in
an account, to promptly obtain and
implement an instruction from the
employee directing that duplicate
account statements be provided by the
member to NASD. Second, NASD Rule
3090(b) prohibits a member from
making any loan of money or securities
to an NASD employee. This prohibition
does not apply to loans made in the
context of disclosed, routine banking
and brokerage agreements, or loans that
are clearly motivated by a personal or
family relationship. Third, NASD Rule
3090(c) prohibits any member from
directly or indirectly giving, or
permitting to be given, anything of more
than nominal value to any NASD
employee who has responsibility for a
regulatory matter involving the member.
This applies regardless of the $100 per
individual per year limitation set forth
in NASD Rule 3060(a). The term
‘‘regulatory matter’’ is defined to
include, without limitation,
examinations, disciplinary proceedings,
membership applications, listing
applications, delisting proceedings, and
dispute-resolution proceedings that
involve the member.
12 See Securities Exchange Act Release No. 55765
(May 15, 2007), 72 FR 28743 (May 22, 2007) (notice)
see also Amendment No. 3 to File No. SR–NASD–
2006–044 (January 2, 2008).
13 Telephone conference among Gary Goldsholle
and Adam Arkel, FINRA, and Haimera Workie,
Branch Chief, Alicia Goldin, Special Counsel,
Sharon Lawson, Senior Special Counsel and Steve
Kuan, Special Counsel, Commission, on September
11, 2008.
14 These interpretative letters are currently
available at FINRA’s web site at https://
www.finra.org/Industry/Regulation/Guidance/
InterpretiveLetters/ConductRules/index.htm.
15 See, e.g., letter to Henry H. Hopkins and Sarah
McCafferty, T. Rowe Price Investment Services,
Inc., dated June 24, 1999.
PO 00000
Frm 00077
Fmt 4703
Sfmt 4703
The NYSE rules governing conflicts of
interest involving NYSE employees
differ from the NASD approach in two
ways. First, rather than applying the
duplicate statement approach to NYSE
employees (which applies to NASD
employees under NASD Rule 3090(a)),
NYSE Rule 407(a) prohibits a member or
member organization, without the prior
written consent of the NYSE, from
opening a securities or commodities
account or executing any transaction in
which an employee of the NYSE is
directly or indirectly interested.16 NYSE
Rule 401.10 states that an employee of
the NYSE or any of its affiliated
companies who wishes to open a
securities or commodities account
should apply for permission from the
NYSE’s Ethics Officer. Second, the
NYSE Rules differ from the nominal
value approach set forth in NASD Rule
3090(c) by instead setting procedures for
outside compensation and placing a
dollar limit on gifts. Specifically, with
respect to outside compensation, NYSE
Rule 350(a)(1) prohibits any member,
allied member, member organization or
employee thereof from employing or
compensating any person for services
rendered without the prior consent of
the person’s employer (i.e., the NYSE
with respect to NYSE employees).17
With respect to gifts, NYSE Rule
350(a)(2) prohibits giving any gift or
gratuity in excess of $50 per person per
year to any principal, officer, or
employee of the NYSE or its
subsidiaries without the prior written
consent of the NYSE. This rule is
written without regard to whether the
NYSE employee has responsibility for
regulatory matters affecting the member.
(2) Proposal
FINRA proposed to transfer NASD
Rule 3090 into the Consolidated FINRA
Rulebook without material change,18
renumbered as FINRA Rule 2070 and
that the corresponding provisions in
NYSE Rules 350(a)(1), 350(a)(2), 350.10,
16 NYSE Rule 407(a) requires duplicate
confirmations and account statements with respect
to accounts or transactions of members, allied
members and employees associated with another
member or member organizations.
17 NYSE Rule 350.10 provides that requests for
NYSE consent under Rule 350(a)(1) should be sent
to the NYSE’s Human Resources Department at
least 10 days in advance of the proposed date of
employment. NYSE Rule 350.10 states that approval
to employ an NYSE employee outside the hours of
regular employment by the NYSE will be limited to
employment of a routine or clerical nature. NYSE
Rule 350.10 further states that when the NYSE has
granted permission for part-time employment of a
NYSE employee, no approval is required for a
subsequent gratuity or bonus to such person
provided it is in proportion to gratuities given to
full-time employees of the employing organization.
18 The proposal included stylistic edits to NASD
Rule 3090 for purposes of clarity and readability.
E:\FR\FM\02OCN1.SGM
02OCN1
Federal Register / Vol. 73, No. 192 / Thursday, October 2, 2008 / Notices
407(a) and 407.10 be eliminated.19
Rather than requiring the member to
obtain FINRA’s consent to open a
securities or commodities account or
execute a trade (as set forth under NYSE
Rules 407(a) and 407.10), FINRA
believes that it is sufficient, as set forth
under NASD Rule 3090(a), to continue
to require the member to obtain and
implement an instruction from the
FINRA employee directing the member
to provide duplicate statements to
FINRA. The proposed rule change
would, as set forth in NASD Rule
3090(b), continue to prohibit members
from making any loan of money or
securities to a FINRA employee, subject
to the exceptions set forth in that rule.
Lastly, the proposed rule change would,
as set forth in NASD Rule 3090(c),
continue to prohibit members from
directly or indirectly giving, or
permitting to be given, anything above
nominal value to any FINRA employee
who has responsibility for a ‘‘regulatory
matter’’ involving the member. FINRA
does not believe that its employees
should be permitted to receive gifts of
up to $50 per year when such
employees have responsibility for a
regulatory matter. In addition, FINRA
proposed not to adopt the $50 limit in
NYSE Rule 350(a)(2) for gifts to all other
employees to maintain consistency with
the FINRA Code of Conduct, which, like
NASD Rule 3060(a) (and proposed
FINRA Rule 3220(a)), establishes a $100
limit. Rule 3090(c) need not be amended
to address the employment and
compensation issues as to NYSE
employees in NYSE Rules 350(a)(1) and
350.10 because the FINRA Code of
Conduct addresses these issues through
its provisions on Outside Activities or
Employment.
FINRA proposed to delete listing and
delisting proceedings as potential
‘‘regulatory matters’’ under NASD Rule
3090(c) in light of FINRA’s separation
from NASDAQ and The American Stock
Exchange.
III. Comment Letters
The Commission received one
comment letter on the proposal 20 and a
response to comments from FINRA.21 In
its comment letter, SIFMA supported
FINRA’s effort to consolidate its two
mstockstill on PROD1PC66 with NOTICES
19 With
respect to NYSE Rule 407(a), the only
change to the rule at this stage in the rulebook
consolidation would be to delete language
pertaining to employees of the NYSE. See Exhibit
5. NYSE Rule 407.10 would be deleted in its
entirety. With respect to NYSE Rules 350(a)(1),
350(a)(2) and 350.10, see supra notes 10 and 11.
20 See supra, footnote 5.
21 See letter from Gary L. Goldsholle, Vice
President and Associate General Counsel, FINRA
Regulatory Group, dated September 11, 2008.
VerDate Aug<31>2005
17:52 Oct 01, 2008
Jkt 217001
rulebooks.22 However, SIFMA suggested
that FINRA should amend the proposed
rule change with respect to NASD Rule
3060 to incorporate a principles-based
approach to gifts and gratuities.23
SIFMA said that FINRA should permit
firms to establish their own gifts and
gratuities policies and limits rather than
retain the limits set forth in the rule.24
SIFMA also supports the inclusion of a
safe harbor in new Rule 3220, under
which a FINRA member firm would be
deemed to be in compliance with new
Rule 3220, if the aggregate annual
amount of gifts and gratuities to any one
person did not exceed a de minimis
amount, such as $250.25
FINRA responded to the request by
SIFMA for a principles-based approach
to gifts and gratuities by stating that
FINRA had given a great deal of
consideration to this approach, but had
determined to maintain the existing
standards, which offer predictability
and clarity.26 FINRA also noted that it
does not believe that it is appropriate at
this time to increase the limit for gifts
and gratuities to $250 from $100.27
57395
V. Conclusion
It is therefore ordered, pursuant to
Section 19(b)(2) of the Act,30 that the
proposed rule change (SR–FINRA–
2008–027) be, and hereby is, approved.
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.31
Florence E. Harmon,
Acting Secretary.
[FR Doc. E8–23196 Filed 10–1–08; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
Release No. 34–58661; File No. SR–FINRA–
2008–030]
Self-Regulatory Organizations;
Financial Industry Regulatory
Authority, Inc.; Order Approving
Proposed Rule Change To Adopt
FINRA Rule 3130 (Annual Certification
of Compliance and Supervisory
Processes) in the Consolidated FINRA
Rulebook
IV. Discussion and Findings
September 26, 2008.
After careful review, the Commission
finds that the proposed rule change is
consistent with the requirements of the
Act, and the rules and regulations
thereunder that are applicable to a
national securities association.28 In
particular, the Commission believes that
the proposed rule change is consistent
with the provisions of Section 15A(b)(6)
of the Act,29 which requires, among
other things, that FINRA rules must be
designed to prevent fraudulent and
manipulative acts and practices, to
promote just and equitable principles of
trade, and, in general, to protect
investors and the public interest. The
Commission believes that, as part of the
FINRA rulebook consolidation process,
the proposed rule change would
streamline and reorganize existing rules
that govern influencing or rewarding the
employees of others and transactions
involving FINRA employees. Further,
the proposed rule change would provide
greater regulatory clarity with respect to
these issues.
I. Introduction
22 See
SIFMA letter.
23 Id.
On June 18, 2008, the Financial
Industry Regulatory Authority, Inc.
(‘‘FINRA’’) (f/k/a National Association
of Securities Dealers, Inc. (‘‘NASD’’))
filed with the Securities and Exchange
Commission (‘‘Commission’’), pursuant
to Section 19(b)(1) of the Securities
Exchange Act of 1934 (‘‘Act’’) 1 and Rule
19b–4 thereunder,2 a proposed rule
change to adopt NASD Rule 3013
(Annual Certification of Compliance
and Supervisory Processes) and IM–
3013 (Annual Compliance and
Supervision Certification) as a FINRA
rule in the consolidated FINRA
rulebook (‘‘Consolidated FINRA
Rulebook’’) 3 without material change,
and to delete the corresponding
provisions in Incorporated NYSE Rule
342.30 and NYSE Rule Interpretations
311(b)(5)/04 through /05 and 342.30(d)/
01 through (e)/01.4 The proposed rule
change would renumber NASD Rule
3013 and IM–3013 as FINRA Rule 3130
in the Consolidated FINRA Rulebook.
The proposed rule change was
published for comment in the Federal
24 Id.
30 15
25 Id.
26 See
27 Id.
28 In approving this proposal, the Commission has
considered the proposed rule’s impact on
efficiency, competition and capital formation. See
15 U.S.C. 78c(f).
29 15 U.S.C. 78o–3(b)(6).
PO 00000
Frm 00078
Fmt 4703
U.S.C. 78s(b)(2).
CFR 200.30–3(a)(12).
1 15 U.S.C. 78s(b)(1).
2 17 CFR 240.19b–4.
3 See infra note 7 for discussion about the
Consolidated FINRA Rulebook.
4 See infra note 7 regarding ‘‘Incorporated NYSE
Rules.’’
31 17
supra, footnote 21.
Sfmt 4703
E:\FR\FM\02OCN1.SGM
02OCN1
Agencies
[Federal Register Volume 73, Number 192 (Thursday, October 2, 2008)]
[Notices]
[Pages 57393-57395]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: E8-23196]
-----------------------------------------------------------------------
SECURITIES AND EXCHANGE COMMISSION
[Release No. 34-58660; File No. SR-FINRA-2008-027]
Self-Regulatory Organizations: Financial Industry Regulatory
Authority, Inc.; Order Approving Proposed Rule Change Relating to the
Adoption of FINRA Rule 3220 (Influencing or Rewarding Employees of
Others) and FINRA Rule 2070 (Transactions Involving FINRA Employees) in
the Consolidated FINRA Rulebook
September 26, 2008.
I. Introduction
On July 18, 2008, the Financial Industry Regulatory Authority, Inc.
(``FINRA'') (f/k/a National Association of Securities Dealers, Inc.
(``NASD'')) filed with the Securities and Exchange Commission
(``Commission'') pursuant to Section 19(b)(1) of the Securities
Exchange Act of 1934 (``Act'')\1\ and Rule 19b-4 thereunder,\2\ a
proposed rule relating to the adoption of FINRA Rule 3220 (Influencing
or Rewarding Employees of Others) and FINRA Rule 2070 (Transactions
Involving FINRA Employees) in the new consolidated FINRA rulebook
(``Consolidated FINRA Rulebook'').\3\ The proposed rule change was
published for comment in the Federal Register on August 11, 2008.\4\
The Commission received one comment letter in response to the proposed
rule change.\5\ This order approves the proposed rule change.
---------------------------------------------------------------------------
\1\ 15 U.S.C. 78s(b)(1).
\2\ 17 CFR 240.19b-4.
\3\ The current FINRA rulebook consists of two sets of rules:
(1) NASD Rules and (2) rules incorporated from NYSE (``Incorporated
NYSE Rules'') (together referred to as the ``Transitional
Rulebook''). The Incorporated NYSE Rules (hereinafter, ``NYSE
Rules'') apply only to those members of FINRA that are also members
of the NYSE (``Dual Members''). Dual Members also must comply with
NASD Rules. For more information about the rulebook consolidation
process, see FINRA Information Notice, March 12, 2008 (Rulebook
Consolidation Process).
\4\ See Securities Exchange Act Release No. 34-58308 (August 5,
2008); 73 FR 46664 (Aug. 11, 2008) (notice).
\5\ See letter from Amal Aly, Managing Director and Associate
General Counsel, Securities Industry and Financial Markets
Association, dated Sept. 2, 2008 (``SIFMA letter'').
---------------------------------------------------------------------------
II. Description of the Proposed Rule Change
As part of the process of developing the Consolidated FINRA
Rulebook, FINRA proposed to transfer without material change NASD Rules
3060 (Influencing or Rewarding Employees of Others) and 3090
(Transactions Involving Association and American Stock Exchange
Employees) into the Consolidated FINRA Rulebook and to delete the
corresponding provisions in Incorporated NYSE Rules 350, 350.10,
407(a), 407.10 and NYSE Rule Interpretations 350/01 through 350/03. The
proposed rule change would renumber NASD Rule 3060 as FINRA Rule 3220
and NASD Rule 3090 as FINRA Rule 2070 in the Consolidated FINRA
Rulebook, and would delete NASD Rules 3060 and 3090 in their entirety
from the Transitional Rulebook.
(A) Proposed FINRA Rule 3220
(1) Background
NASD Rule 3060 (Influencing or Rewarding Employees of Others)
currently states that no member or associated person shall give gifts
or gratuities to an agent or employee of another person in excess of
$100 per year where the gift or gratuity is in relation to the business
of the employer of the recipient. The rule, which protects against
improprieties that may arise when members or their associated persons
give gifts or gratuities to employees of a customer, has been in effect
in its current form since 1969, with changes only to the dollar
amounts, rising from $25 to $50 to $100.\6\ The rule requires each
member to maintain a separate record of all gifts or gratuities. The
rule also contains an express exclusion for payments made pursuant to
bona fide, written employment contracts.
---------------------------------------------------------------------------
\6\ See NASD Notice to Members 93-8 (February 1993) (SEC
Approval of Amendment Relating to the Payment of Gratuities or
Anything of Value by Members to Others); see also Securities
Exchange Act Release No. 21074 (June 20, 1984), 49 FR 26330 (June
27, 1984) (SR-NASD-84-8) (approval order).
---------------------------------------------------------------------------
NYSE Rule 350 (Compensation or Gratuities to Employees of Others)
reaches similar conduct in prohibiting, absent prior written consent of
the recipient's employer, any member or member organization from giving
any gratuity in excess of $100 per person per year to any principal,
officer, or employee of another member or member organization,
financial institution, news or financial information media, or non-
member broker or dealer in securities, commodities or money
instruments.\7\ NYSE Rule 350 has specific provisions addressing
compensation to operations employees of members (e.g., NYSE Floor
personnel). In addition, NYSE Rule 350 requires that records of all
such gratuities and compensation be retained for at least three years.
---------------------------------------------------------------------------
\7\ In addition, NYSE Rule 350(a)(1) prohibits any member from
employing or compensating any person for services rendered except
with the prior consent of that person's employer. FINRA proposed to
delete this provision, even though it does not pertain to gifts,
because a substantively identical provision exists in NYSE Rule
346(b). FINRA intends to review NYSE Rule 346(b) as part of a later
phase of the rulebook consolidation process.
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(2) Proposal
FINRA proposed to transfer NASD Rule 3060 into the Consolidated
FINRA Rulebook without material change and renumbered as FINRA Rule
3220. One of the advantages of the existing regulatory standard is the
clarity of the rule's application--it prevents gifts in excess of a
fixed amount, currently $100. Both the NASD and NYSE rules have a $100
limitation on gifts.
FINRA believes that NASD Rule 3060 generally is well understood by
members. FINRA recently issued additional guidance on NASD Rule 3060 in
Notice to Members 06-69.\8\ Among the issues addressed in that Notice
was the fact that NASD Rule 3060 does not apply to gifts of de minimis
value, or to promotional items of nominal value
[[Page 57394]]
displaying a firm's logo. The Notice stated that NASD Rule 3060 does
not prohibit customary Lucite tombstones, plaques or other similar
solely decorative items commemorating a business transaction or event.
The Notice also stated that gifts should be valued at the higher of
cost or market value and tickets should be valued at the higher of cost
or face value. In addition, FINRA staff has used its interpretive
authority to address unintended consequences of the rule, such as
unreasonable limitations on giving a bereavement or sympathy gift.\9\
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\8\ See NASD Notice to Members 06-69 (December 2006) (Gifts and
Gratuities).
\9\ See Interpretive Letter dated December 17, 2007 to Amal Aly,
SIFMA from Gary L. Goldsholle, FINRA, available at: https://
www.finra.org/RulesRegulation/PublicationsGuidance/
InterpretiveLetters/ConductRules/P037695.
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FINRA proposed to eliminate the provision in NYSE Rule 350
permitting member firms to obtain prior written consent of the
recipient's employer for any gift over $100. FINRA believes that the
gift rule should establish a fixed amount and does not see any business
need to justify giving gifts in amounts greater than the limits
specified in the rule. FINRA also would delete the provisions in NYSE
Rule 350 and NYSE Rule Interpretation 350/02 addressing compensation to
operations/Floor employees of NYSE as they are not relevant for
FINRA.\10\ For similar reasons, provisions in NYSE Rule 350.10
pertaining to employment of or gratuities to personnel working the
Floor of other exchanges would be deleted.\11\ Finally, FINRA would
eliminate the provisions of NYSE Rule 350 relating to record retention,
as NASD Rule 3060(c) addresses the same issue. FINRA proposed to
eliminate NYSE Rule Interpretation 350/01, and provisions in NYSE Rule
350.10 pertaining to gifts among close relatives, because the concepts
contained in both are adequately addressed by proposed FINRA Rule 3220
and existing guidance. Lastly, FINRA would eliminate NYSE Rule
Interpretation 350/03 because FINRA has proposed a separate rule that
addresses business entertainment.\12\ Any guidance provided under NASD
Rule 3060, including, without limitation, notices to members and
interpretation letters, also would apply to the proposed FINRA Rule
3220.\13\ The Commission notes three interpretative letters previously
issued with respect to NASD Rule 3060.\14\ The interpretative letters
include FINRA's rule on members providing business entertainment.\15\
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\10\ NYSE Rule Interpretation 350/02 would be deleted in its
entirety. Note that NYSE Rule 350 also contains provisions that
address gifts and gratuities to employees of the NYSE. These
provisions are addressed in connection with FINRA's proposal to
adopt FINRA Rule 2070. See Section (B) under Item II.A.1. FINRA's
proposals with respect to FINRA Rules 3220 and 2070 would, in
combination, delete NYSE Rule 350 in its entirety.
\11\ NYSE Rule 350.10 also contains provisions that address
employment or compensation of NYSE employees by members or member
organizations. These provisions are addressed in connection with
FINRA's proposal to adopt FINRA Rule 2070. See Section (B) under
Item II.A.1. Because Proposed FINRA Rules 3220 and 2070 would
address the substance of NYSE Rule 350.10, FINRA proposed to delete
NYSE Rule 350.10 in its entirety.
\12\ See Securities Exchange Act Release No. 55765 (May 15,
2007), 72 FR 28743 (May 22, 2007) (notice) see also Amendment No. 3
to File No. SR-NASD-2006-044 (January 2, 2008).
\13\ Telephone conference among Gary Goldsholle and Adam Arkel,
FINRA, and Haimera Workie, Branch Chief, Alicia Goldin, Special
Counsel, Sharon Lawson, Senior Special Counsel and Steve Kuan,
Special Counsel, Commission, on September 11, 2008.
\14\ These interpretative letters are currently available at
FINRA's web site at https://www.finra.org/Industry/Regulation/
Guidance/InterpretiveLetters/ConductRules/index.htm.
\15\ See, e.g., letter to Henry H. Hopkins and Sarah McCafferty,
T. Rowe Price Investment Services, Inc., dated June 24, 1999.
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(B) Proposed FINRA Rule 2070
(1) Background
Both NASD and NYSE rules address conflicts of interest involving
FINRA and NYSE employees.
NASD Rule 3090 addresses this issue in three ways. First, NASD Rule
3090(a) requires a member, when it has actual notice that an NASD
employee has a financial interest or controls trading in an account, to
promptly obtain and implement an instruction from the employee
directing that duplicate account statements be provided by the member
to NASD. Second, NASD Rule 3090(b) prohibits a member from making any
loan of money or securities to an NASD employee. This prohibition does
not apply to loans made in the context of disclosed, routine banking
and brokerage agreements, or loans that are clearly motivated by a
personal or family relationship. Third, NASD Rule 3090(c) prohibits any
member from directly or indirectly giving, or permitting to be given,
anything of more than nominal value to any NASD employee who has
responsibility for a regulatory matter involving the member. This
applies regardless of the $100 per individual per year limitation set
forth in NASD Rule 3060(a). The term ``regulatory matter'' is defined
to include, without limitation, examinations, disciplinary proceedings,
membership applications, listing applications, delisting proceedings,
and dispute-resolution proceedings that involve the member.
The NYSE rules governing conflicts of interest involving NYSE
employees differ from the NASD approach in two ways. First, rather than
applying the duplicate statement approach to NYSE employees (which
applies to NASD employees under NASD Rule 3090(a)), NYSE Rule 407(a)
prohibits a member or member organization, without the prior written
consent of the NYSE, from opening a securities or commodities account
or executing any transaction in which an employee of the NYSE is
directly or indirectly interested.\16\ NYSE Rule 401.10 states that an
employee of the NYSE or any of its affiliated companies who wishes to
open a securities or commodities account should apply for permission
from the NYSE's Ethics Officer. Second, the NYSE Rules differ from the
nominal value approach set forth in NASD Rule 3090(c) by instead
setting procedures for outside compensation and placing a dollar limit
on gifts. Specifically, with respect to outside compensation, NYSE Rule
350(a)(1) prohibits any member, allied member, member organization or
employee thereof from employing or compensating any person for services
rendered without the prior consent of the person's employer (i.e., the
NYSE with respect to NYSE employees).\17\ With respect to gifts, NYSE
Rule 350(a)(2) prohibits giving any gift or gratuity in excess of $50
per person per year to any principal, officer, or employee of the NYSE
or its subsidiaries without the prior written consent of the NYSE. This
rule is written without regard to whether the NYSE employee has
responsibility for regulatory matters affecting the member.
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\16\ NYSE Rule 407(a) requires duplicate confirmations and
account statements with respect to accounts or transactions of
members, allied members and employees associated with another member
or member organizations.
\17\ NYSE Rule 350.10 provides that requests for NYSE consent
under Rule 350(a)(1) should be sent to the NYSE's Human Resources
Department at least 10 days in advance of the proposed date of
employment. NYSE Rule 350.10 states that approval to employ an NYSE
employee outside the hours of regular employment by the NYSE will be
limited to employment of a routine or clerical nature. NYSE Rule
350.10 further states that when the NYSE has granted permission for
part-time employment of a NYSE employee, no approval is required for
a subsequent gratuity or bonus to such person provided it is in
proportion to gratuities given to full-time employees of the
employing organization.
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(2) Proposal
FINRA proposed to transfer NASD Rule 3090 into the Consolidated
FINRA Rulebook without material change,\18\ renumbered as FINRA Rule
2070 and that the corresponding provisions in NYSE Rules 350(a)(1),
350(a)(2), 350.10,
[[Page 57395]]
407(a) and 407.10 be eliminated.\19\ Rather than requiring the member
to obtain FINRA's consent to open a securities or commodities account
or execute a trade (as set forth under NYSE Rules 407(a) and 407.10),
FINRA believes that it is sufficient, as set forth under NASD Rule
3090(a), to continue to require the member to obtain and implement an
instruction from the FINRA employee directing the member to provide
duplicate statements to FINRA. The proposed rule change would, as set
forth in NASD Rule 3090(b), continue to prohibit members from making
any loan of money or securities to a FINRA employee, subject to the
exceptions set forth in that rule. Lastly, the proposed rule change
would, as set forth in NASD Rule 3090(c), continue to prohibit members
from directly or indirectly giving, or permitting to be given, anything
above nominal value to any FINRA employee who has responsibility for a
``regulatory matter'' involving the member. FINRA does not believe that
its employees should be permitted to receive gifts of up to $50 per
year when such employees have responsibility for a regulatory matter.
In addition, FINRA proposed not to adopt the $50 limit in NYSE Rule
350(a)(2) for gifts to all other employees to maintain consistency with
the FINRA Code of Conduct, which, like NASD Rule 3060(a) (and proposed
FINRA Rule 3220(a)), establishes a $100 limit. Rule 3090(c) need not be
amended to address the employment and compensation issues as to NYSE
employees in NYSE Rules 350(a)(1) and 350.10 because the FINRA Code of
Conduct addresses these issues through its provisions on Outside
Activities or Employment.
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\18\ The proposal included stylistic edits to NASD Rule 3090 for
purposes of clarity and readability.
\19\ With respect to NYSE Rule 407(a), the only change to the
rule at this stage in the rulebook consolidation would be to delete
language pertaining to employees of the NYSE. See Exhibit 5. NYSE
Rule 407.10 would be deleted in its entirety. With respect to NYSE
Rules 350(a)(1), 350(a)(2) and 350.10, see supra notes 10 and 11.
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FINRA proposed to delete listing and delisting proceedings as
potential ``regulatory matters'' under NASD Rule 3090(c) in light of
FINRA's separation from NASDAQ and The American Stock Exchange.
III. Comment Letters
The Commission received one comment letter on the proposal \20\ and
a response to comments from FINRA.\21\ In its comment letter, SIFMA
supported FINRA's effort to consolidate its two rulebooks.\22\ However,
SIFMA suggested that FINRA should amend the proposed rule change with
respect to NASD Rule 3060 to incorporate a principles-based approach to
gifts and gratuities.\23\ SIFMA said that FINRA should permit firms to
establish their own gifts and gratuities policies and limits rather
than retain the limits set forth in the rule.\24\ SIFMA also supports
the inclusion of a safe harbor in new Rule 3220, under which a FINRA
member firm would be deemed to be in compliance with new Rule 3220, if
the aggregate annual amount of gifts and gratuities to any one person
did not exceed a de minimis amount, such as $250.\25\
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\20\ See supra, footnote 5.
\21\ See letter from Gary L. Goldsholle, Vice President and
Associate General Counsel, FINRA Regulatory Group, dated September
11, 2008.
\22\ See SIFMA letter.
\23\ Id.
\24\ Id.
\25\ Id.
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FINRA responded to the request by SIFMA for a principles-based
approach to gifts and gratuities by stating that FINRA had given a
great deal of consideration to this approach, but had determined to
maintain the existing standards, which offer predictability and
clarity.\26\ FINRA also noted that it does not believe that it is
appropriate at this time to increase the limit for gifts and gratuities
to $250 from $100.\27\
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\26\ See supra, footnote 21.
\27\ Id.
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IV. Discussion and Findings
After careful review, the Commission finds that the proposed rule
change is consistent with the requirements of the Act, and the rules
and regulations thereunder that are applicable to a national securities
association.\28\ In particular, the Commission believes that the
proposed rule change is consistent with the provisions of Section
15A(b)(6) of the Act,\29\ which requires, among other things, that
FINRA rules must be designed to prevent fraudulent and manipulative
acts and practices, to promote just and equitable principles of trade,
and, in general, to protect investors and the public interest. The
Commission believes that, as part of the FINRA rulebook consolidation
process, the proposed rule change would streamline and reorganize
existing rules that govern influencing or rewarding the employees of
others and transactions involving FINRA employees. Further, the
proposed rule change would provide greater regulatory clarity with
respect to these issues.
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\28\ In approving this proposal, the Commission has considered
the proposed rule's impact on efficiency, competition and capital
formation. See 15 U.S.C. 78c(f).
\29\ 15 U.S.C. 78o-3(b)(6).
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V. Conclusion
It is therefore ordered, pursuant to Section 19(b)(2) of the
Act,\30\ that the proposed rule change (SR-FINRA-2008-027) be, and
hereby is, approved.
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\30\ 15 U.S.C. 78s(b)(2).
For the Commission, by the Division of Trading and Markets,
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pursuant to delegated authority.\31\
Florence E. Harmon,
Acting Secretary.
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\31\ 17 CFR 200.30-3(a)(12).
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[FR Doc. E8-23196 Filed 10-1-08; 8:45 am]
BILLING CODE 8011-01-P