6.1.6. Non-Cash Compensation
With regard to publicly traded DPP offerings, FINRA imposes limits on the ability of a broker-dealer or associated person to give or receive non-cash compensation. The rule’s definition of non-cash compensation includes travel expenses, meals, and lodging. To be allowable, non-cash compensation must fall into at least one of these categories:
• Business entertainment, such as an occasional meal or a ticket to a sporting event. To use this exemption, the entertainment must be neither so frequent nor so extensive as to raise any question of propriety.