COMPLIANCE
Gift & Entertainment Compliance: Know Your Limits
Gifts and entertainment can create real or perceived conflicts of interest — which is exactly why the SEC and our own Compliance Manual pay close attention to them. As we head into a season with more client dinners, conference invitations, and holiday gestures on the calendar, this is a good moment to revisit where the lines are drawn.
The Core Rule
Each IAR or Employee may give or receive up to $500 in gifts per client, per calendar year, without needing prior approval. Anything above that threshold requires prior written approval from Compliance. Cash and cash-equivalents (including non-specific gift cards) are never permitted, regardless of dollar amount.
GIFTS vs. ENTERTAINMENT — What's the difference?
Gift: Something of value given or received when you are not present with the other party (e.g., a bottle of wine sent to an office, event tickets you don't attend together).
Entertainment: A business event both and the other party attend together (e.g., a dinner meeting, a round of golf) centered on a bona fide business discussion.
Quick Reference
Category | Limit | Approval Needed? |
Gifts (general) | $500 aggregate / client / year | Above $500: yes, prior written approval |
Cash or cash-equivalents | Never permitted | N/A — always prohibited |
Entertainment | Reasonable, customary, not lavish | Excessive/frequent entertainment may require pre-approval |
Public pension officials | ≤$50/occurrence, ≤$150/year; no travel/lodging | Yes — prior Compliance approval always required |
De minimis items | $50 or less (e.g., branded items, pens, mugs) | Excluded from aggregation, but must still be reasonable |
Don’t forget to Log it
Every gift and entertainment item — given or received — must be reported in the Firm's Gifts & Entertainment log no later than the end of the calendar quarter in which it occurred. Logging promptly (rather than waiting until quarter-end) makes it much easier to track your running total against the $500 threshold. For Triad Wealth Partners IARs, this is logged in Greenboard, which can be uploaded via a spreadsheet.
A Few Reminders
• Aggregation applies: Gifts and entertainment are aggregated per client household or entity, so keep a running tally, not just a per-event view.
• When in doubt, ask first: if you're unsure whether something crosses the line, ask Compliance before it happens, not after.
Questions about a specific gift, entertainment plan, or client event?
Reach out to Cody Augustus or Dani Hampton in Compliance before moving forward — we're happy to help you think it through.
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