NASD Rule 2290 Disclosures and Procedures Concerning the Issuance of Fairness Opinions. October 21, 2006. Rick Lacher Houlihan Lokey Howard & Zukin Investment Banking Services 200 Crescent Court, Suite 1900 Dallas, TX 75201 Phone: (214) 220-8490 [email protected] NASD Rule 2290.
Any NASD member issuing a fairness opinion that may be provided, or described, or otherwise referenced to public shareholders must disclose, to the extent not otherwise required, in such fairness opinion:
Any member issuing a fairness opinion must have procedures that address the process by which a fairness opinion is approved by a firm, including:
In the SEC’s Request for Comment, the SEC specifically notes:
There were fewer responses than in the NASD’s original request: