Joe Cool Is a Member of the All Greek Fraternity

Joe Cool is a member of the All Greek Fraternity. A few of the alumni of his fraternity sat for the FINRA Series 6 exam over the past couple of years and, using their cell phones, took pictures of the exam questions. They forwarded these to their fraternity to be included in the test bank file the fraternity keeps in its study room. Have there been any violations of FINRA/NASD rules in this instance?

A) No. It is standard practice for sororities and fraternities to compile test banks of old exams, and since the forwarded tests are not copies of an actual future exam that will be administered, there has been no violation of any rules.
B) Yes. It is a violation of Rule 2110 for an exam-past or present-to be reproduced and distributed for study purposes.
C) No. Rule 2110 only prohibits the reproduction and distribution of a previously administered FINRA exam for study purposes if the exams are being sold. As long as there is no compensation involved, a violation has not been committed.
D) Both A and C are true statements.