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Publications


Robert J. Smith and Margaret M. Riley have co-authored the following articles:

  • Amendments to NASD Rules Governing Member Communications with the Public, NSCP Currents, September/October 2003
  • NASD Replaces Hot Issues Interpretation with New Equity Public Offerings Rule, NSCP Currents, January/February 2004
  • Variable Life Settlements, NSCP Currents, July/August 2007


Robert J. Smith is co-author of the following articles:

  • The NASD’s Proposed Roll-Up Rule, Insights, The Corporate & Securities Law Advisor, Volume 7, Number 10, October 1993
  • NASD Ranking Guidelines for Mutual Funds, Securities & Commodities Regulation, Volume 28, Number 2, January 25, 1995
  • SEC Adopts Rules Aimed at Analyst Conflicts of Interest, Securities Regulatory Update, Volume 5, Issue 11, June 10, 2002
  • NASD Proposes Clarifying Best Execution Rule, Securities Regulatory Update, Volume 5, Issue 19, October 7, 2002


Robert J. Smith, while at NASD, was principal author of the following rules/amendments:

  • IM-2210-3: Mutual Funds Rankings
  • IM-2210-5: Bond Fund Volatility Ratings
  • Rule 2211: Institutional Sales Material and Correspondence
  • Rule 2810: Limited Partnership Roll-Up Transactions
  • Rule 2820: Non-Cash Compensation – Variable Contracts
  • Rule 2830: Non-Cash Compensation – Mutual Funds
  • Rule 3230: Clearing and Carrying Agreements


Robert J. Smith, while at NASD, authored interpretive letters for the following rules:

  • Rule 2210: Communications with the Public
  • IM-2110-1: Free-Riding and Withholding
  • Rule 2330: Customers’ Securities or Funds
  • Rule 2420: Dealing with Non-Members
  • IM-2420-2: Continuing Commissions Policy
  • Rule 2820: Variable Contracts of an Insurance Company
  • Rule 2830: Investment Company Securities
  • Rule 3010: Supervision
  • Rule 3110: Books and Records


Robert J. Smith, while at NASD, authored the following Notices
to Members:

  • NASD Notice to Members 00-44: The NASD Reminds Members of Their Responsibilities Regarding the Sale of Variable Life Insurance
  • NASD Notice to Members 00-23: SEC Approves New Rules Relating to Bond Mutual Fund Volatility Ratings
  • NASD Notice to Members 98-107: NASD Reminds Members of Their Obligations to Disclose Mutual Fund Fees
  • NASD Notice to Members 98-098: SEC Approves Rule Change Relating to Mutual Fund Breakpoint Sales
  • NASD Notice to Members 98-083: SEC Approves Rule Change Relating to Standards for Individual Correspondence
  • NASD Notice to Members 98-075: SEC Approves Rule Change Relating to Non-Cash Compensation for Mutual Funds and Variable Products
  • NASD Notice to Members 98-054: SEC Approves Rule Change Regarding Approval of Research Reports
  • NASD Notice to Members 98-047: SEC Approves Changes to Books and Records Requirements
  • NASD Notice to Members 97-79: NASD Regulation Requests Comment on Proposed Amendment to Rule Governing Clearing Agreements
  • NASD Notice to Members 97-60: SEC Approves New Procedures for Granting Exemptions to NASD Rules
  • NASD Notice to Members 97-50: NASD Regulation Requests Comment on Regulation of Payment and Receipt of Cash Compensation Incentives
  • NASD Notice to Members 97-48: NASD Regulation Requests Comment on Amendments to Rules Governing Sale and Distribution of Investment Company Shares and Variable Insurance Products
  • NASD Notice To Members 97-47: NASD Regulation Requests Comment on Presentation of Related Performance Information
  • NASD Notice To Members 97-37: NASD Regulation Requests Comment on Proposed Definition of Correspondence for Rules Regarding Communications with the Public
  • NASD Notice to Members 97-28: Approval of Investment Company Rankings Amendments
  • NASD Notice to Members 97-27: Application of NASD Conduct Rules to Group Variable Contracts and Other Exempted Securities
  • NASD Notice to Members 97-01: Approval of Telemarketing Amendments
  • NASD Notice to Members 96-86: NASD Regulation Reminds Members and Associated Persons that Sales of Variable Contracts are Subject to NASD Suitability Requirements
  • NASD Notice to Members 96-68: NASD Solicits Member Comment on Proposed Rules Relating to Prospectus Disclosure of Cash and Non-Cash Compensation for the Sale of Investment Company Securities
  • NASD Notice to Members 96-52: NASD Solicits Member Comments on Proposed Rules Relating to the Sale of Variable Life Insurance Contracts and Variable Annuity Contracts
  • NASD Notice to Members 96-44: NASD Interprets NASD Rule 2110 and Files Telemarketing Rule Changes with SEC
  • NASD Notice to Members 96-14: SEC Approves Amendments to Sections 1(a)(v) and 73 of NASD Uniform Practice Code Relating to the Use of Standardized Limited Partnership Transfer Forms
  • NASD Notice to Members 95-74: SEC Approves Amendments to Advertising and Sales Literature Filing and Review Requirements
  • NASD Notice to Members 95-64: SEC Approves Amendments to Article III, Section 34 of the NASD Rules of Fair Practice and Part I of Schedule D to the NASD By-Laws Relating to Limited Partnership Rollup Transactions
  • NASD Notice to Members 95-63: SEC Approves Amendments to Article III, Section 34 of the NASD Rules of Fair Practice Relating to Freely Tradeable Direct Participation Program Securities
  • NASD Notice to Members 95-56 -- NASD Files with the SEC Proposals Related to Non-Cash Incentive Programs, Disclosure of Cash Compensation, and Direct Payments to Associated Persons
  • NASD Notice to Members 95-22: SEC Approves Amendments to Article III, Section 44 of the NASD Rules of Fair Practice About Filing Requirements for Modified Guaranteed Annuity and Life Insurance Contracts
  • NASD Notice to Members 94-67: NASD Solicits Member Comment on Cash and Non-Cash Compensation for Selling Investment Company and Variable Contract Securities
  • NASD Notice to Members 94-60: SEC Approves Guidelines Relating to the Use of Rankings in Investment Company Advertisements and Sales Literature
  • NASD Notice to Members 94-36: SEC Approves Communication Guidelines for Variable Products
  • NASD Notice to Members 94-25: SEC Approves Amendments to Filing Requirements for Communications Regarding Mutual Fund Rankings and CMOs
  • NASD Notice to Members 94-7: SEC Approves New NASD Rule Relating to the Obligations and Responsibilities of Introducing and Clearing Firms
  • NASD Notice to Members 93-86: SEC Approves Amendment to Section 65(f)(1) of the Uniform Practice Code Relating to Resolution of Fails Resulting from Account Transfers
  • NASD Notice to Members 93-76: NASD Solicits Member Vote on Filing Requirements for Use of Mutual Fund Rankings and Elimination of Sunset Provisions in Prefiling Requirements for CMO Advertisements
  • NASD Notice to Members 93-50: Proposed New Section to the Rules of Fair Practice Relating to the Respective Obligations and Supervisory Responsibilities of Introducing and Clearing Firms

 

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