Tracking employees adherence to their firm’s gifts and entertainment policies has become more challenging during the COVID-19 pandemic, where virtual events have become the norm. Amy Lynch, FrontLine’s Founder and President, states that pre-pandemic, firms could more easily monitor employees, with direct reporting to compliance within an office environment. Ms. Lynch adds that while there has been some recent regulatory guidance, firm policies on attendance, meals and gifts at virtual entertainment or video type events require the same adherence to the FINRA “gifts rule.” Some firms, such as Merrill Lynch, have moved to amend policies and eliminate third party provided gifts, which is also meant to reduce conflicts of interest in the wake of Reg BI. See FundFire (subscription required), “Merrill Lynch Cracks Down on Third-Party Gifts”
Gifts and entertainment polices under review in virtual environment (FundFire)
FrontLine Compliance
