Matt is a registered representative with Fine, Howard, Fine and Associates. Tom, an old fraternity brother, is one of his clients. Business has been bad, and Matt is going to have difficulties making this month’s mortgage payment. Tom was commiserating with him when the two hooked up to have a couple of beers together and offered to lend Matt some money to see him through the rough times. Based on these facts:
Explanation
Answer: B - Since Tom and Matt are old fraternity brothers, Matt may accept Tom’s offer, but only after obtaining pre-approval from Fine, Howard, Fine. FINRA’s Rule 3240 allows for borrowing and lending between a registered representative and a client if “the lending arrangement is based on a personal relationship with the customer, such that the loan would not have been solicited, offered, or given had the customer and the associated person not maintained a relationship outside of the broker/customer relationship.”
