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.

Whether you can do this depends on the services provided by your Investment Department. Are these non-licensed persons making referrals to licensed employees for broker-dealer services or NDIPs? If so, I agree that you need to stick with the basic referral fee. The guidance was pretty clear--can't even have the pizza party anymore. Look at Reg R Sec. 218.700 "Defined terms relating to the networking exception from the definition of "broker."