During the holiday season, and throughout the year, many registered representatives (“RRs”) and associated persons (i.e. fingerprinted persons) give or receive gifts. While ESI allows for the giving and receiving of gifts, we want to remind everyone that there are limitations and reporting responsibilities imposed on the giving and receipt of gifts. Business-related gifts given or received must be reported to your supervisor and Compliance through Star Compliance (“Star”).
What to Report/What Not to Report
All gifts to/from clients, business partners, product sponsors, and prospects must be reported.
- Gifts given/received to/from any individual/firm may not exceed $100 per person per calendar year.
- Gifts to labor union employees and public officials require PRIOR approval.
- Gifts given/received before, during, or after entertainment must be reported.
- Consumable gifts (e.g. food, wine), even if a promotional item, must be reported.
- Gifts given to home office employees must be reported.
- If expensing a gift or treating the gift as a business expense, the gift must be reported.
- Reporting of gifts should be done within two weeks of giving or receiving.
The following are NOT required to be reported:
- Promotional items under $75 (items with a company logo).
- Gifts given to employees or other RRs within your own office.
- Personal gifts to immediate family members who also happen to be customers, where the gift is unrelated to the Firm’s business, and occasional personal gifts to others not taken as a business expense.
How to Report
Go to https://nationallife.starcompliance.com:
- Your Login is your 5-digit rep code. If you do not recall your password, you may click “Forget your password” to reset it. Once in Star, click the “Gifts” box to report a gift.
- For instructions on how to complete the form, please refer to the below links:
- INSTRUCTIONS – Gift Given
- INSTRUCTIONS – Gift Received
Delegation of Reporting
If you wish to have a non-registered fingerprinted person (“NRF”) complete your gift logs, they may enter them for you in Star as a “proxy”. To have them designated as your gift proxy in Star, please email ESICompliance@nationallife.com with their contact information.
Questions?If you have questions, please feel free to contact Ben Zarzycki in ESI Compliance at 802-229-3659 or bzarzycki@nationallife.com.
TC124739(1221)1