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Gifts to clients

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Nov 22, 2010 11:18 pm

Greenbacks2

Joined: 2010-03-03Offline

As many of you are aware Goldman Sachs along with other firms and reps are able to fly there clients to New York or wherever.  And spend thousands of dollars on each client.  But FINRA rules state that firms can spend only $100 per client or $300 per client event. How can these firms and some reps get away with this?

Nov 24, 2010 12:38 pm

stockattorney

Joined: 2010-09-09Offline

The $100 rule is direct compensation whereas the transportation, taking them to dinner or taking them to a sporting event will naturally exceed the $100 and is considered incidental.  Your compliance policy should cover the ground rules regarding this.