The New York Stock Exchange and the NASD may have unveiled extensive guidance last week to clarify their rules on gift-giving and entertainment between company and client, but their advice really boils down to three words: use your head.
Answering a question that has vexed compliance officers and bar-hopping traders alike, the two trading exchanges ordered their member companies to devise, document and implement their own prudent policies—but left the exact definition of “prudent” to the companies themselves.
