Question

Difficulty: Very hardGifts, Gratuities, Political Contributions, and Outside Business Activities

Under FINRA Rule 3220, a registered representative who purchases two 150concertticketsusingpersonalfundsandgivesthemtoacorporatecustomerwithoutaccompanyingthecustomertotheperformanceremainsexemptfromthe150 concert tickets using personal funds and gives them to a corporate customer without accompanying the customer to the performance remains exempt from the 100 annual gift limit because the representative did not seek firm reimbursement.

Answer: Answer

Answer

False. Under FINRA Rule 3220, event tickets provided to a client without representative attendance are classified as a gift subject to the $100 annual limit per recipient. Paying for the gift with personal funds does not exempt the transaction from regulatory restrictions.
The statement is false. FINRA Rule 3220 limits gifts given in connection with securities business to $100 per recipient per year. When tickets are provided without representative attendance, they are classified as a gift rather than business entertainment. Paying with personal funds does not exempt the gift from FINRA oversight.

Step-by-Step Solution

1
Classify the nature of the transaction (entertainment vs. gift).
Because the registered representative does not accompany the customer to the concert, the tickets cannot be treated as business entertainment; they are classified as a gift.
FINRA Rule 3220 requires host attendance for event tickets to qualify under business entertainment guidelines.
2
Evaluate the value against statutory limits.
The total value of 300exceedsthemaximumannuallimitof300 exceeds the maximum annual limit of 100 per recipient.
FINRA Rule 3220 restricts gifts given by an associated person in relation to the business of the employer to $100 per individual per year.
3
Determine the legal impact of using personal funds without firm reimbursement.
Personal payment does not exempt the gift from FINRA Rule 3220.
The rule applies to any gift related to the business of the member firm, regardless of the source of funding or reimbursement.

Key Concept

FINRA Rule 3220 Gifts and Gratuities Restrictions
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