FINRA recently accepted the offer of
settlement of a St. Louis member firm. The uncontested offer of
settlement was submitted approximately 9 months after FINRA's
Department of Enforcement filed its Complaint. Enforcement accused
the firm of improperly gifting tickets to various sporting events to
employees of municipal securities issuers. The firm gifted over
$2,000 tickets valued at almost $200,000 in a two-year period.
In concluding that the firm violated
MSRB Rule G-27, FINRA emphasized three salient factors: 1) the firm
did not host the recipients of the tickets at the events, 2) the firm
gifted tickets only to those issuers who were clients, and 3) the
bigger issuers received more and better tickets. MSRB Rule G-20 has
an exemption for occasional gifts of tickets that requires the member
firm to host the event. As a result, the St. Louis firm was censured
and fined $200,000. Food for Thought! Go to the game!
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