Institute Comment Letter on NASDR Correspondence Rule Proposal

Washington, DC, July 14, 1997 - The Institute recently submitted a comment letter to NASD Regulation, Inc. regarding proposed amendments to NASD Conduct Rule 2210 that would require written and electronic communications prepared for a single customer to meet certain of Rule 2210's content requirements.

The Institute's comment letter opposes the proposal on the ground that it is unnecessary and inappropriate and therefore should not be adopted. This position is based upon ICI's belief that: (1) existing NASD Conduct Rules governing member correspondence with individual customers are more than sufficient to curb any perceived wrongful conduct; (2) imposing the requirements of Rule 2210 on correspondence would be highly inappropriate in many contexts; and (3) the implementation of the proposed amendments would add another extremely costly and burdensome layer of regulation applicable to NASD members without any corresponding benefit to consumers.