Legal Question in Securities Law in New York

I run a Registered Investment Adviser with the SEC. We are NOT registered as a broker dealer with FINRA or affiliated with one. We would like to give clients rewards based on a point system (i.e. $50,000 account would accumulate 50,000 points) which can be redeemed for rewards such as travel, restaurants etc. Clients would also get points for referring other clients.

Is there anything illegal about doing this? From my understanding gifting rules only apply to advisers attached to broker dealers.


Asked on 7/28/15, 9:19 am

1 Answer from Attorneys
SHAHRIAR KASHANIAN LAW OFFICES OF SHAHRIAR KASHANIAN, ESQ.,

Your question should be posed to SEC and await their official response. You may want to provide the SEC with several options and await their approval of your submissions.

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Answered on 7/28/15, 9:25 am


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