The year-end holiday season is a time many service providers see as an opportunity to bolster client relationships with something as simple as a greeting card or perhaps a gift.
Financial advisors, who increasingly understand the importance of providing clients personalized service, can enhance these relationships by sending a gift at the holidays.
For a selection of tasteful, high-quality gifts, they can turn to Secretly Gifting, a gift concierge company founded by Ashley Bronczek and Candace Ourisman that specializes in creative gifting solutions for corporations and individuals.
However, advisors must be aware of rules and guidelines from the Financial Industry Regulatory Authority and the Securities and Exchange Commission that constrain gift-giving to clients.
FINRA generally prohibits advisors from bestowing gifts in excess of $100 per individual, per year. The rule carves out an exception for personal gifts — a wedding gift or a congratulatory gift for the birth of a child, for example — provided that such gifts are not “in relation to the business of the employer of the recipient.”
As for RIA firms, gifting is most often regulated by reference to the anti-fraud provision of the Investment Advisors Act and the fiduciary duties an advisor owes to its clients.
It is common for RIAs to loosely adopt the FINRA rule for broker-dealers, rule 3220, which must be adhered to if the firm contains bill registrants. Firms can set a nominal value higher than $100, but should have guidelines around this practice.
The National Retail Federation has predicted that holiday retail sales during November and December will increase between 3.8% and 4.2% year over year to a total of between $728 billion and $731 billion. This compares with an average holiday sales increase of 3.7% over the previous five years.
Check out the gallery for some gift ideas — all under $100 — from Secretly Gifting.