The Financial Industry Regulatory Authority (FINRA) issued an FAQ on whether FINRA Rule 3220 (Influencing or Rewarding Employees of Others) and the non-cash compensation provisions of FINRA Rules 2310, 2320, 2341 and 5110 would prohibit an associated person from hosting a virtual business entertainment event and providing food and beverage to the employees of an institutional customer or third-party broker-dealer. The non-cash compensation rules provide that business entertainment provided by member firms to their clients is not subject to the $100 gift limit set forth in FINRA Rule 3220 as long as it does not raise any question of propriety. Accordingly, FINRA indicated that it would view the associated persons’ provision of reasonable amounts of food and beverage designed to be consumed by the recipient employees and their guests during that virtual business entertainment or meeting as not being subject to the $100 gift limit, provided that it does not raise questions of propriety.

The FAQ is available here.