New York, NY - May 14, 2007, 2007 - The SEC has recently approved changes to the NASDâs rules and interpretive materials regarding Limit Order Protection. Previously, these rules, commonly referred to as Manning, applied only to Nasdaq listed securities and those quoted on the OTCBB. By expanding the interpretation, Manning principles and all the interpretive guidance thereunder will apply to those equity securities quoted on the Pink Sheets, as well as all other-OTC equities (those traded in the âgrey marketâ). Manning generally prohibits an NASD member from trading for its own account in a security at a price that is equal to or better than an unexecuted customer limit order in that security, unless the member immediately thereafter executes the customer limit order at the price at which it traded for its own account or at a better price. A member firm that accepts and holds an unexecuted limit order from its customer (whether its own customer or a customer of another member) in an listed security or OTC equity security and that continues to trade the subject security for its own account at prices that would satisfy the customerâs limit order, without executing that limit order, shall be deemed to have acted in a manner inconsistent with just and equitable principles of trade, in violation of Rule 2110 (IM-2110-2). However, a member firm may negotiate specific terms and conditions applicable to the acceptance of limit orders that are: (a) for customer accounts that meet the definition of an âinstitutional accountâ as that term is defined in Rule 3110(c)(4); or (b) 10,000 shares or more, unless such orders are less than $100,000 in value. In the event that a member trades ahead of an unexecuted customer limit order at a price that is better than the unexecuted limit order, such member is required to execute the limit order at the price received by the member or better. Nothing in this interpretation, however, requires members to accept limit orders from any customer. This change is effective on July 26, 2007. To view the changes to IM-2110-2, please see Notice to Members 07-19 [PDF] For further information about IM-2110-2 or Limit Order Protection, please contact us by email at email@example.com, or contact Michael T. Dorsey, Esq., Managing Director, Trading Services & Compliance at 212-896-4456.