Submit Non-Cash Compensation - Independence Square Advisors

IAR's Name *

First

Last

Date of Compensation *

Did you give or receive a gift or business entertainment? *

To me from (I received the Gift or Entertainment)
From me to (I gave the gift or Entertainment)

Name (First, Last) *

Name of the person providing or receiving the gift/entertainment to/from you. (Client, Prospect, or wholesaler, etc.)

Organization

Only provide an organization if the gift or business entertainment is being provided or was received by a Product Sponsor.

Type of compensation given/received: *

If you selected "other", please provide a description of what was received or given.

Cash may never be given or accepted and gift cards must be redeemable for goods or services. Gift cards such as Visa, American Express, MasterCard are considered a 'cash equivalent' and are generally not permitted except for Life Events as described later in this section.

Was the Non-Cash Compensation: *

A gift not to exceed $100 per person, aggregated per year that is applicable to associated persons under FINRA 3220 or MSRB G-20.
A gift not to exceed $500 per person, aggregated per year that is not subject to FINRA 3220 or MSRB G-20 (For Hybrid Advisors, all gifts above $100 must be pre-approved by LPL prior to giving or accepting such a gift.)
A gift not to exceed $1,000 per person, aggregated per year pursuant to LPL's "Life Event" Policy? (Events should be generally infrequent, based on a personal relationship and be personal in nature. Examples of events that may qualify for the exemption include (but are not limited to) weddings, births, bereavements or milestone celebrations (e.g., baptism, bar/bat mitzvah, or Quinceanera, etc.). In addition, gifts for life events may not be reimbursed by a Sponsor or LPL, such reimbursement would indicate the gift is business related and is not personal in nature.)
A gift not to exceed $1,000 per person, aggregated per year pursuant to LPL's "Pre-existing relationship" Policy? (Gifts given or received to/from individuals for which it can be established that the relationship between the parties pre-dates that of the advisor-client relationship if the gift is given for some other purpose outside of the advisor-client relationship.)
Business Entertainment Provided by or received by Advisors to/from a Clients? ($500 per client (including with or without guest) / $2,000 annually)
Business Entertainment Provided by/to Sponsors to/from Advisors/OSJs. ($2,000 annually per giver or recipient)
Business Entertainment Provided Virtually. ($2,000 annually per donor/recipient)
Lunch and Learn Business Entertainment. ($500 per year per sponsor at a max of $250 per event)
Sponsor and/or Vendor Support? (Up to $500 multiplied by the number of qualified individuals in attendance.)

________________________________________________________________________________________________________________________________FINRA Rule 3220: No member or person associated with a member shall, directly or indirectly, give or permit to be given anything of value, including gratuities, in excess of one hundred dollars per individual per year to any person, principal, proprietor, employee, agent or representative of another person where such payment or gratuity is in relation to the business of the employer of the recipient of the payment or gratuity. A gift of any kind is considered a gratuity. ________________________________________________________________________________________________________________________________ MSRB G-20 No regulated entity or any of its associated persons shall, directly or indirectly, give or provide or permit to be given or provided any thing or service of value, including gratuities, in excess of $100 per year to a person (other than an employee or partner of such regulated entity), if such payments or services are in relation to the municipal securities or municipal advisory activities of the employer of the recipient of the payment or service. For purposes of this rule the term "employer" shall include a principal for whom the recipient of a payment or service is acting as agent or representative.

If you selected "Life Event."

Please describe the life event.

If you selected "Pre-existing Relationship."

Please provide a brief description of the pre-existing relationship and when the advisor/client relationship began.

Location *

City / State

Establishment/Retailer *

This might be the name of the establishment where the business entertainment was provided or this could be the retailer where the gift was purchased through.

Dollar amount of the gift or business entertainment. *

All gifts must be valued at the greater of the cost in terms of what the giver paid, or its fair market or face value.

Was the amount entered above, the *

Exact Amount?
Approximate Amount?

Any supporting documentation.

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