On April 8, 2014, FINRA published Regulatory Notice 14-15, requesting comment on firms’ experiences with FINRA’s rules on Gifts and Gratuities and Non-Cash Compensation. FINRA is conducting a retrospective review of these rules to assess their effectiveness and efficiency. The comments will inform FINRA’s decision as to whether the rules remain relevant and are appropriately designed to achieve their objectives.
A review of the Gifts and Gratuities and Non-Cash Compensation is a good place to start with, because there has been some confusion in the past with the $100 gift limit, how best to comply with it and other questions on what constitutes appropriate gifts and incentives within the industry.
We fully support FINRA’s efforts to conduct this review, because it helps ensure that the process of compliance evolves with changing market conditions, and in parallel with other factors. We also plan to comment on this notice and will be encouraging our members to contact us to provide feedback on these rules, so stay tuned for more on this issue as it develops.