[Federal Register Volume 59, Number 110 (Thursday, June 9, 1994)] [Unknown Section] [Page 0] From the Federal Register Online via the Government Publishing Office [www.gpo.gov] [FR Doc No: 94-14031] [[Page Unknown]] [Federal Register: June 9, 1994] ----------------------------------------------------------------------- SECURITIES AND EXCHANGE COMMISSION [Release No. 34-34151; File No. SR-NASD-94-19] Self-Regulatory Organizations; National Association of Securities Dealers, Inc.; Order Approving Proposed Rule Change to Provide the NASD With Discretionary Authority to Exclude an Issuer From the Nasdaq Stock Market or Impose Additional or More Stringent Criteria for Inclusion in the Nasdaq Stock Market June 3, 1994. I. Introduction On April 6, 1994, the National Association of Securities Dealers, Inc. (``NASD'' or ``Association'') filed with the Securities and Exchange Commission (``SEC'' or ``Commission'') a proposed rule change pursuant to Section 19(b)(1) of the Securities Exchange Act of 1934 (``Act'')\1\ and Rule 19b-4 thereunder.\2\ The rule change adds provisions to Schedule D to the NASD By-Laws clarifying the NASD's discretionary authority to exclude an issuer from the Nasdaq Stock Market (``Nasdaq'') or require additional or more stringent criteria for inclusion in Nasdaq. --------------------------------------------------------------------------- \1\15 U.S.C. 78s(b)(1) (1988). \2\17 CFR 240.19b-4 (1993). --------------------------------------------------------------------------- Notice of the proposed rule change together with its terms of substance was provided by issuance of a Commission release and by publication in the Federal Register.\3\ Three comments were received in response to the Commission release, one expressing general support and two opposing the proposal. This order approves the proposed rule change. --------------------------------------------------------------------------- \3\Securities Exchange Act Release No. 33899 (Apr. 12, 1994), 59 FR 18171 (Apr. 15, 1994). --------------------------------------------------------------------------- II. Description According to the NASD, it submitted this rule filing primarily to address concerns about the increasing number of applications for inclusion in Nasdaq by companies controlled or substantially influenced by persons with a history of securities or commodities violations.\4\ The NASD also indicated that its proposal to amend Sections 1 and 2 of Part II to Schedule D\5\ is intended to codify certain principles underlying Nasdaq. First, the NASD states, that as operator of Nasdaq, it is entrusted with the authority to preserve and strengthen the quality of and public confidence in its market. Second, Nasdaq stands for integrity and ethical business practices in order to enhance investor confidence, thereby continuing to the financial health of the economy, and supporting the capital formation process. Third, inclusion in Nasdaq carries with it an implicit expectation that all Nasdaq issuers, from new public companies to companies of international stature, share these objectives. The proposal further clarifies that the NASD, in addition to applying the enumerated criteria set forth in Parts II and III to Schedule D, may exercise broad discretionary authority over the initial and continued inclusion of securities in Nasdaq in order to maintain the quality of and public confidence in its market. Under this broad discretion, and in addition to its authority under Subsection 3(a), the proposal notes that the NASD may deny initial inclusion or apply additional or more stringent criteria for the initial or continued inclusion of particular securities or suspend or terminate the inclusion of particular securities based on any event, condition, or circumstance which exists or occurs that makes initial or continued inclusion of the securities in Nasdaq inadvisable or unwarranted in the opinion of the NASD, even though the securities meet all enumerated criteria for initial or continued inclusion in Nasdaq. --------------------------------------------------------------------------- \4\In addition, this rule change corrects a technical deficiency in the NASD's rules. The proposal amends Part II, Section 3(a) of Schedule D to the NASD's By-Laws which currently provides the NASD, under certain circumstances, with the authority to apply additional or more stringent criteria for the initial or continued inclusion of particular securities or to suspend or terminate the inclusion of a security otherwise qualified for inclusion in Nasdaq. For many years, the NASD has interpreted Section 3(a) to authorize the NASD to deny inclusion of a security in Nasdaq. The NASD believes authority to deny inclusion is inherent in Section 3(a), otherwise the NASD would be required to include a security in Nasdaq in order to terminate the security's inclusion. The NASD has determined that its authority to deny inclusion of particular securities in Nasdaq in compliance with the enumerated provisions of Section 3(a) should be stated expressly. The proposed rule change, therefore, amends Part II, Section 3(a) of Schedule D to clarify this authority. \5\NASD Manual, Schedules to the By-Laws, Schedule D, Part II, Secs. 1 & 2, (CCH) 1803 & 1804. Nasdaq includes both Nasdaq SmallCap Market and Nasdaq National Market securities. Sections 1 and 2 to Part II of Schedule D include the qualification requirements for domestic and Canadian securities and for non- Canadian foreign securities and American Depositary Receipts, respectively. The qualification requirements in Sections 1 and 2 of Part II to Schedule D apply to both the Nasdaq SmallCap Market and Nasdaq National Market securities. --------------------------------------------------------------------------- The NASD is concerned about an increase in recent years in the number of applications for inclusion in Nasdaq by issuers that are managed, controlled or influenced by persons with a history of significant securities or commodities violations.\6\ In particular, the NASD is concerned about issuers substantially influenced by persons who have previously been the subject of a significant sanction for violations of state or federal securities laws, self-regulatory organization (``SRO'') rules and regulations, or the subject of a felony conviction in connection with the purchase or sale of securities or commodities. The NASD believes that applications from these issuers for inclusion in Nasdaq reflect a pattern of activity in which persons with a history of securities or commodities violations seek to continue their violative conduct in the securities markets through the management, control or influence of a publicly-held company. The NASD has indicated that a case-by-case review of issuer applications has previously resulted in denials of certain applications pursuant to the ``catch-all'' provision of Part II, Section 3(a)(3) of Schedule D.\7\ --------------------------------------------------------------------------- \6\As a result of its concerns, on June 2, 1993, the NASD filed a proposal to amend Part II, Section 3(a). Securities Exchange Act Release No. 32605 (July 9, 1993), 58 FR 38150 (July 15, 1993) (Commission notice of File No. SR-NASD-93-32). Concurrent with the filing of the instant proposal, the NASD withdrew File No. SR-NASD- 93-32. Letter from T. Grant Callery, Vice President and General Counsel, NASD, to Mark P. Barracca, Branch Chief, SEC (Apr. 6, 1994). \7\Section 3(a)(3) provides that ``[t]he Association may, in accordance with Article IX of the NASD's Code of Procedure, apply additional or more stringent criteria for the initial or continued inclusion of particular securities or suspend or terminate the inclusion of an otherwise qualified security if * * * the Association deems it necessary to prevent fraudulent and manipulative acts and practices, to promote just and equitable principles of trade, or to protect investors and the public interest.'' NASD Manual, Schedules to the By-Laws, Schedule D, Part II, Sec. 3(a)(3), (CCH) 1805 (``Section (3)(a)(3)''). --------------------------------------------------------------------------- In exercising discretion about whether to include an issuer in Nasdaq, the NASD will form a reasonable belief as to whether certain persons connected with an issuer may be predisposed to engage in further violative conduct contrary to interests of the investing public. In these cases, the NASD believes that the history of prior violative conduct raises concerns regarding the continuing potential for conduct in connection with the operation of the company or the market for its securities that would be considered fraudulent and manipulative, contrary to just and equitable principles of trade, or otherwise raise investor protection concerns. The NASD's concern regarding situations where a person with a history of securities or commodities law violations manages, controls or influences a Nasdaq issuer is heightened by the fact that inclusion of the securities of such issuers in Nasdaq would exempt the transactions in these securities from Commission rules adopted to prevent certain fraud and abuse in the penny stock market. In August 1989, the Commission adopted Rule 15c2-6 to address sales practice abuses in low priced over-the-counter (``OTC'') securities.\8\ In general, this rule prohibits broker-dealers from selling a ``designated security'' to, or effecting the purchase of a ``designated security'' by, any person, unless the broker-dealer has approved the purchaser's account for such transactions and received from the purchaser a written agreement to the transaction.\9\ On April 10, 1992, the Commission adopted the Penny Stock Disclosure Rules\10\ which, in general, require that broker-dealers: (1) Furnish to a customer a risk disclosure document; (2) disclose the current bid and ask quotations and the commissions; and (3) provide monthly updates on the value of the securities. Among other exemptions, the Commission excluded from the scope of Rule 15c2-6 and the Penny Stock Disclosure Rules all issuers authorized or approved for inclusion in Nasdaq. The NASD believes that continued vigilance is required to ensure that inclusion in Nasdaq is not used as a vehicle to avoid compliance with the Penny Stock Disclosure Rules. The NASD further believes that prospective investors in the securities of a Nasdaq company are entitled to assume that securities included in Nasdaq meet the system's standards.\11\ --------------------------------------------------------------------------- \8\Securities Exchange Act Release No. 27160 (Aug. 22, 1989), 54 FR 35468 (Aug. 28, 1989). \9\17 CFR 240.15c2-6(a). \10\The Penny Stock Sales Practice and Disclosure Rules of the Act are comprised of Rule 3a51-1 providing definitions of penny stocks and Rules 15g-1 to 15g-6, 15g-8 and 15g-9. In general, the Penny Stock Rules have been enacted to require more stringent regulation of broker-dealers that recommend penny stock transactions to customers. Under Rule 3a51-1 of the Act, Nasdaq securities are excluded from the scope of the Penny Stock Disclosure Rules, except that Nasdaq SmallCap securities under $5.00 are deemed penny stocks for purposes of Section 15(b)(6) of the Act. See, Securities Exchange Act Release No. 30608 (Apr. 20, 1992), 57 FR 18004 (Apr. 28, 1992). \11\See In the Matter of Tassaway, Inc., Securities Exchange Act Release No. 11291 (Mar. 13, 1975), 45 SEC 706, 6 SEC Docket 427 (``primary emphasis must be placed on the interests of prospective future investors''). --------------------------------------------------------------------------- III. Comments As noted above, the Commission received three comment letters in response to the NASD's proposed rule change. The Task Force on Listing Standards of Self-Regulatory Organizations of the Federal Regulation of Securities Committee, Section of Business Law of the American Bar Association (``ABA Task Force'') expressed general support for the NASD's initiative, but indicated concern over the retroactive application of the NASD's rule. In particular, the ABA Task Force is concerned that the NASD may exclude a current issuer based on a previously disclosed condition. The ABA Task Force believes that the NASD should only apply the rule retroactively to issuers where there is a change in control, disclosure of new material information, or other meaningful change in circumstance.\12\ A second commenter opposed the proposal, asserting that the discretion accorded the NASD was unlimited and could lead the NASD to exclude an issuer from Nasdaq on a basis wholly unrelated to the legitimate concerns of administering Nasdaq.\13\ Finally, a third commenter argued that the NASD's comparison to the NYSE and Amex rules is misplaced. In particular, this commenter argued that the rules of these exchanges provide greater procedural protection to issuers in that an appeal within the NYSE or Amex provides an automatic stay of the initial decision but does not with an appeal within the NASD of an NASD decision.\14\ --------------------------------------------------------------------------- \12\Letter from John F. Olson, Chair, Committee on Federal Regulation of Securities, ABA Section on Business Law, and Robert Todd Lang, Chair, Task Force on Listing Standards of Self-Regulatory Organizations, ABA Section on Business Law, to Jonathan G. Katz, Secretary, SEC (Apr. 29, 1994). According to the letter, it was prepared by members of the ABA Task Force, circulated among the members and a substantial majority of the members agree with it. Nonetheless, the letter indicated that it does not represent the official position of the ABA, the Section of Business Law, the Federal Regulation of Securities Committee or the ABA Task Force. \13\Letter from Andrew I. Telsey to Jonathan G. Katz, Secretary, SEC (Apr. 26, 1994). This commenter also asserted that the proposal was tantamount to a prior restraint on speech and a violation of the United States Constitution's guarantee of free speech. The Commission is convinced that the proposal, as designed, will have no such consequences. The NASD's proposal is similar in many respects to that of existing authority vested in other securities markets. \14\Letter from Joseph McLaughlin, Brown & Wood, to Jonathan G. Katz, Secretary, SEC (May 6, 1994). --------------------------------------------------------------------------- The NASD responded to these comments in letters dated May 17 and May 25, 1994.\15\ With respect to the concerns of the ABA Task Force, the NASD believes that limiting this authority to prospective issuers or to issuers undergoing a material change in circumstance would inappropriately restrict its oversight of Nasdaq and hinder its review of individual issuers. In addition, the NASD believes that prospective investors are entitled to assume that the NASD protects the quality and integrity of Nasdaq.\16\ --------------------------------------------------------------------------- \15\Letters from T. Grant Callery, Vice President and General Counsel, NASD, to Mark P. Barracca, Branch Chief, SEC (May 17, 1994) and Suzanne E. Rothwell, Associate General Counsel, NASD, to Mark P. Barracca, Branch Chief, SEC (May 25, 1994). \16\In connection with its prior proposal, SR-NASD-93-32, the NASD responded to a similar comment by the ABA Task Force by stating that limiting its discretion in the suggested manner would impose an arbitrary restriction on the NASD's oversight of Nasdaq. This, the NASD argued, could undermine public confidence in Nasdaq and would be contrary to interests of retail and institutional investors, issuers, broker-dealers and the public. See Securities Exchange Act Release No. 33899 (Apr. 12, 1994), 59 FR 18171 (Apr. 15, 1994) (Commission notice of File No. SR-NASD-94-19); File No. SR-NASD-93- 32, Amendment No. 2 (File No. SR-NASD-93-32 was withdrawn by the NASD concurrent with the filing of File No. SR-NASD-94-19). --------------------------------------------------------------------------- The NASD also believes that assertions that the proposed rule would provide the NASD boundless discretion are unwarranted. First, the nature and scope of the NASD's discretionary authority is set forth in the proposed new language. In addition, any determination to exclude an issuer will be made on a case-by-case basis in accordance with the procedures set forth in Article IX of the NASD's Code of Procedure,\17\ and an aggrieved party may request the NASD to review its initial determination.\18\ In addition, the NASD indicated that an issuer may request, or the NASD may voluntarily grant, a stay pending appeal within the NASD. Indeed, in the past, the NASD has delayed immediate delisting when the matter presented novel policy issues. Finally, if the aggrieved party is dissatisfied with a final determination of the NASD, it may then request that the Commission stay the NASD's action, and ultimately it may obtain review of the Commission's final order in the United States Court of Appeals. --------------------------------------------------------------------------- \17\NASD Manual, Code of Procedure, Art. IX, Sec. 1, (CCH) 3101. The NASD also noted that its Code of Procedure has been subject to public notice and comment, Securities Exchange Act Release No. 19097 (Oct. 4, 1982), 47 FR 44903 (Oct. 12, 1982) (Commission notice of SR-NASD-82-11), and has been approved by the Commission, Securities Exchange Act Release No. 21838 (Mar. 12, 1985), 50 FR 11035 (Mar. 19, 1985) (Commission approval of SR-NASD- 82-11). The NASD also noted that its authority to exclude an issuer or to impose additional or more stringent criteria under the proposed rule is substantially similar to the authority it currently exercises under Section 3(a)(3). \18\NASD Manual, Code of Procedure, Art. IX, Secs. 6 & 8, (CCH) 3106 & 3108. --------------------------------------------------------------------------- IV. Discussion Under Section 19(b) of the Act, the Commission must approve a proposed NASD rule change if it finds that the proposal is consistent with the requirements of the Act and the rules and regulations thereunder that govern the NASD.\19\ No other finding is required.\20\ In evaluating a given proposal, the Commission must examine the record before it and all relevant factors and necessary information.\21\ Section 15A of the Act addresses with some specificity the requirements applicable to NASD rules, and those are the standards against which the Commission must measure the NASD proposal.\22\ --------------------------------------------------------------------------- \19\15 U.S.C. 78s(b). \20\The Commission's statutory role is limited to evaluating the rule as proposed against the statutory standards, and does not require the SRO to prove its proposal is the least burdensome solution to a problem. \21\In the Securities Acts Amendments of 1975 (``1975 Amendments''), Congress directed the Commission to use its authority under the Act, including its authority to approve SRO rule changes, to foster the establishment of a national market system and promote the goals of economically efficient securities transactions, fair competition, and best execution. Congress granted the Commission ``broad, discretionary powers'' and ``maximum flexibility'' to develop a national market system and to carry out these objectives. Furthermore, Congress gave the Commission ``the power to classify markets, firms, and securities in any manner it deems necessary or appropriate in the public interest or for the protection of investors and to facilitate the development of subsystems within the national market system.'' S.Rep. No. 75, 94th Cong., 1st. Sess., at 7 (1975). \22\See 15 U.S.C. 78o-3. --------------------------------------------------------------------------- The Commission has determined to approve the NASD's proposal. The Commission believes that the rule change is consistent with the requirements of the Act and the rules and regulations thereunder applicable to the NASD, including the requirements of Sections 15A (b)(6) and 15A (b)(9) of the Act.\23\ Section 15A(b)(6) requires, in part, that the rules of a national securities association be designed to prevent fraudulent and manipulative acts and practices, to promote just and equitable principles of trade, and, in general, to protect investors and the public interest. Section 15A(b)(9) requires that the NASD's rule not impose any burden on competition not necessary or appropriate in furtherance of the Act. In addition, the Commission believes that the rule change will further the goals of Section 11A in that it will help preserve and strengthen the nation's securities markets.\24\ --------------------------------------------------------------------------- \23\Id. Sec. 78o-3(b) (6) and (9). \24\Id. Sec. 78k-1(a)(1)(A). --------------------------------------------------------------------------- The Commission believes that inclusion of a security for trading in Nasdaq, like listing on an exchange, should not depend solely on meeting quantitative criteria, but should also entail an element of judgment given the expectations of investors and the imprimatur of listing on a particular market.\25\ Securities listed for trading or included in Nasdaq often qualify for margin loans and are exempt from many of the state blue sky laws, which apply concepts of merit regulation to determine whether investors in that state may purchase the issuer's securities. --------------------------------------------------------------------------- \25\See e.g., In the Matter of Silver Shield Mining and Milling Company, Securities Exchange Act Release No. 6214 (Mar. 18, 1960) (``use of the facilities of a national securities exchange is a privilege involving important responsibilities under the Exchange Act''); In the Matter of Consolidated Virginia Mining Co., Securities Exchange Act Release No. 6192 (Feb. 26, 1960) (same). --------------------------------------------------------------------------- Almost twenty years ago, the Commission held in In the Matter of Tassaway\26\ that the NASD is vested with discretionary authority to deny an issuer's request that its securities be included in Nasdaq. In that decision, the Commission stated that while exclusion from Nasdaq may hurt existing shareholders, the primary emphasis must be placed on the interest of prospective public investors and that this latter group is entitled to assume that the securities in Nasdaq meet the NASD standards. Although the Commission is of the view that the NASD's current rules authorize it to exclude an issuer, the proposal would clarify that authority. The Commission believes that this rule change provides greater protection to both existing and prospective investors. This rule change provides investors greater assurance that the risk associated with investing in Nasdaq is market risk rather than the risk that the promoter or other persons exercising substantial influence over the issuer is acting in an illegal manner. --------------------------------------------------------------------------- \26\Securities Exchange Act Release No. 11291 (Mar. 13, 1975), 45 SEC 706, 6 SEC Docket 427. --------------------------------------------------------------------------- The rule change will address the increase of applications by issuers for inclusion in Nasdaq where a person with a history of significant securities or commodities law violations is in a position to manage, control or influence the issuer to the detriment of investors. The rule change also responds to the related concern that inclusion of these securities in Nasdaq would exempt the transactions in these securities from Commission rules adopted to prevent certain fraudulent sales practices and abuses in the penny stock market.\27\ The Commission agrees that with respect to the Nasdaq SmallCap Market, the rule change furthers the purposes of the Penny Stock Rules adopted under the Act. The rule change will provide the NASD with authority to ensure that securities which would otherwise be subject to the Penny Stock Rules merit this exemption when entering Nasdaq and continue to merit this exemption thereafter. --------------------------------------------------------------------------- \27\See Letter from Richard G. Ketchum, Director, Division of Market Regulation, SEC, to Joseph R. Hardiman, President, NASD (Jan. 10, 1990). --------------------------------------------------------------------------- As indicated above, one commenter raised due process concerns. In the context of excluding issuers from Nasdaq, the Commission believes these concerns are addressed by the statutory and regulatory authority and obligations of the NASD. The Act requires the NASD to adopt and enforce rules designed, among other things, to prevent fraudulent and manipulative acts and practices and to protect investors and the public interest.\28\ The Act further requires that the NASD's rules provide a fair procedure when prohibiting or limiting access to Nasdaq,\29\ which includes notification of the specific grounds for prohibiting or limiting access, providing an opportunity to be heard, and maintaining a record.\30\ In accordance with these obligations, the NASD has established quantitative and qualitative criteria for inclusion in Nasdaq,\31\ and procedures to review decisions to deny or limit access to an issuer the NASD determines does not satisfy the criteria for inclusion.\32\ Those procedures provide an opportunity for a hearing\33\ and, although not explicit, an opportunity to request a stay from the NASD. In addition to these obligations, the Act and Commission rules require the NASD to notify the Commission promptly of any final or summary action to prohibit or limit access to Nasdaq.\34\ The Act and Commission rules further provide that any final action by the NASD is subject to review by the Commission.\35\ In addition, the Commission may stay summary action by the NASD on its own motion or upon an application by the issuer.\36\ Finally, a person dissatisfied with a final determination of the Commission may seek review of that decision by the United States Court of Appeals.\37\ --------------------------------------------------------------------------- \28\15 U.S.C. section 78o-3(b)(6). \29\Id. section 78o-3(b)(8). \30\Id. section 78o-3(h)(2). \31\NASD Manual, Schedules to the By-Laws, Schedule D, Parts II & III, (CCH) 1803-1806A & 1807-1813. \32\NASD Manual, Code of Procedure, Art, VIII, Secs. 1-10, (CCH) 3081-3090 (NASD procedures re: summary action prohibiting or limiting access to Nasdaq) and Art. IX, Secs. 1-9, (CCH) 3101- 3109 (NASD procedures re: final action prohibiting or limiting access to Nasdaq). \33\See Belfort v. NASD, No 93-7159, 1994 U.S. Dist. LEXIS 3457 (S.D.N.Y. Mar. 21, 1994) (court lacks jurisdiction because the plaintiff did not exhaust administrative remedies under the Act); Dimensional Visions v. NASD, 799 F. Supp. 29 (E.D. Pa. 1992) (same). \34\15 U.S.C. 78s(d)(1). The Commission rule promulgated pursuant to 15 U.S.C. 78s(d)(1) distinguishes between notice to the Commission of final action excluding an issuer from Nasdaq (17 CFR 240.19d-1(e)) and notice to the Commission of summary action excluding an issuer from Nasdaq (17 CFR 240.19d-1(i)). With respect to notice of final action, the rule requires that it be promptly filed with the Commission and include the name of the issuer and the last known place of business, the statutory and/or regulatory basis for excluding the issuer, a statement describing the issuer's response to the NASD's decision, a statement of the finding of facts and conclusions, a statement supporting the resolution of the principal issues raised, the effective date of the NASD's action and other information the NASD deems relevant. 17 CFR 240.19d-1(f). With respect to notice of summary action, the rule requires that it be filed with the Commission within 24 hours of the effectiveness of the action and include the name of the issuer and the last known place of business, a statement describing the specific statutory basis for summarily excluding the issuer, the effective date of the NASD's action and other information the NASD deems relevant. 17 CFR 240.19d-1(i). \35\15 U.S.C. 78s(d)(2) and 17 CFR 240.19d-3. \36\15 U.S.C. 78o-3(h)(3) and 17 CFR 240.19d-2. \37\Id. section 78y(a)(1). --------------------------------------------------------------------------- The Commission believes that this rule strikes the appropriate balance between protecting investors and providing a marketplace for issuers satisfying the disclosure requirements under the federal securities laws. This rule change clarifies the NASD's current practice of using its authority under Section 3(a)(3) of Part II to Schedule D. The authority granted under Section 3(a)(3) is discretionary in nature and this rule change will continue to allow the NASD to exercise its discretion in applying the standards of Section 3(a)(3) on a case-by- case basis. The rule change will also provide important guidance to the NASD review process, and will alert issuers seeking inclusion in Nasdaq, as well as current Nasdaq issuers, that the NASD considers an issuer's connection to a person with a history of significant securities or commodities violations in determining whether to grant initial or continued inclusion of the security, and that the security may be subject to additional criteria as a condition for initial and continued inclusion in Nasdaq. The rule change establishes the NASD's discretionary authority under Part II, Sections 1 and 2 of Schedule D to deny initial inclusion or apply additional or more stringent criteria for the initial or continued inclusion of particular securities or suspend or terminate the inclusion of particular securities based on any event, condition, or circumstance which exists or occurs that makes initial or continued inclusion of the securities in Nasdaq inadvisable or unwarranted, even though the securities meet all enumerated criteria for initial or continued inclusion in Nasdaq. Nonetheless, the Commission expects that before the NASD exercises its discretionary authority under the new rule, it will consider as one of several factors the extent to which events or circumstances giving rise to the proposed action were previously disclosed. V. Conclusion In conclusion, for the reasons stated above, the Commission finds that the rule change is designed to prevent fraudulent and manipulative acts and practices, to promote just and equitable principles of trade and, in general, to protect investors and the public interest. The Commission therefore finds that the proposed rule change is consistent with the requirements of the Act. It is therefore ordered, pursuant to Section 19(b)(2) of the Act, that the proposed rule change SR-NASD-94-19 be, and hereby is, approved. For the Commission, by the Division of Market Regulation, pursuant to delegated authority.\38\ --------------------------------------------------------------------------- \38\17 CFR 200.30-3(a)(12). --------------------------------------------------------------------------- Margaret H. McFarland, Deputy Secretary. [FR Doc. 94-14031 Filed 6-8-94; 8:45 am] BILLING CODE 8010-01-M