BDA submitted its comment letter to FINRA in response to its request for comment on proposed amendments to its gifts, gratuities, and non-cash compensation rules. You can view FINRA’s regulatory notice here.
FINRA has proposed to consolidate various interpretative guidance documents related to gifts and non-cash compensation into the FINRA rulebook. Additionally, FINRA is proposing to increase its gifts limit from $100 to $175 to account for the rate of inflation since the adoption of the $100 limit. BDA’s letter recommends that FINRA:
- Should not raise its gifts limit, from $100 to $175, in order to remain harmonized with the MSRB to reduce any unnecessary compliance complexity for dealers
- Increase its gift limit to $200, if FINRA deems an increase necessary, to make record keeping easier to track for dealer firms
Other Notable Proposed Amendments
Expanding Non-Cash Compensation Rules:
FINRA has proposed to amend the non-cash compensation rules to cover all securities products
Internal Sales Contests:
FINRA has proposed a revised approach to internal sales contests to be based on total production of all securities
A New Requirement for WSPs:
FINRA proposes a requirement for firms to incorporate business entertainment into their written policies and supervisory procedures
Additional Information
- BDA’s December 2014 comment letter to the MSRB can be reviewed here.
