Rules to Consider
- Non-registered FRs: Each state has different limitations on acceptable levels of gifts giving, with some of those limits being as low as an annual aggregate value of one dollar. In addition, some states consider giving gifts or entertainment as rebating. It is the FR’s responsibility to check the laws and regulations of each state in which they do business to ensure they comply with the specific requirements of those states. Here is one article that may help, and it includes a link to a state-specific resource. Agent Sync Article June 2023
- Registered Representatives: Read the PAS Compliance Manual.
Some key points:
- No cash equivalents (checks, cash, MC/Visa/AMEX gift cards, lottery tickets, etc.)
- Log all given and received gifts in STAR Compliance immediately.
- Value is limited to $100/person/year. This is a regulatory limit.
- Example: If there are two spouses, the limit would be $200 since you can allocate $100 for one and $100 for the other.
- Tax and shipping are excluded. The $100 limit is for the value of the item.
- Promotional gifts with logo valued $50 or less do not need to be disclosed in STAR.
- Aside from promotional gifts with logos, RRs cannot give gifts to product sponsors.
- Use reasonable judgement to determine the value of a gift if the price is not known.
When in doubt, contact our ACO Virginia Brown for clarification.
