We are going to be having an Investment Referral Campaign, and each employee will receive $25 for a qualified referral to the Investment Department (no sales requirement, the person referred just has to have investable assets and keep the appointment).
In addition to the $25 referral fee, the Investment Department would like to reward the top referrer with a prize (less than $100) at the end of the campaign. I don't think we can do this because it would then add to the "nominal" fee already paid and would go against the Interagency Guidance.
Can any of you that have had similar campaigns weigh in to confirm my thoughts or point me to something that says we would be able to do this? I appreciate any help you can offer.
I use to think I was a smart cookie before I started working in Compliance. Now, I have mastered the art of the blank stare!