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Client Alert

NASD Proposes New Interpretative Guidelines Relating To Gifts

February 09, 2006

Investment Management Group

The NASD has proposed new interpretive guidance relating to the provision of gifts and business entertainment by NASD member firms to employees, agents and representatives (and certain other persons) of a member firm’s customers. This guidance, in the form of proposed new interpretative material to NASD Conduct Rule 3060 (Influencing or Rewarding Employees of Others), more explicitly outlines the restrictions related to, and the policies and procedures member firms must adopt in connection with, such business entertainment practices.

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Practice Areas

Investment Management