The Self-Regulatory and Supervisory Practices Committee of the Securities Industry Association (SIA)* provides comments to the National Association of Securities Dealers, Inc. (NASD) on non-cash compensation rules, Notice to Members 05-40.  The proposed rule changes would expand the prohibitions of non-cash compensation to the sale and distribution of any security; and prohibit all product specific sales contests.

The Committee believes the proposal needs additional clarification and modification to ensure the regulation is not inadvertently applied to legitimate business conduct.

*SIFMA is the product of a merger between the Securities Industry Association (SIA) and The Bond Market Association (TBMA) in 2006.