The investigation started when the NASD discovered that the company had implemented national sales contests and that national managers, supervised by Mr. Alonso, pressured regional managers, branch managers and financial advisors. These awards were of a variet

An occasional meal, a ticket to a sporting even or the theater, or comparable entertainment that is neither so frequent nor so extensive as to raise any question or propriety and is not preconditioned on the achievement of sales targets.

Mary Shapiro, president of NASD, the regulatory unit, in a New York Times article, stated, “NASD regulators were surprised to find that Morgan Stanley ignored the rules to eliminate the contests from practically the moment the rules were written.”¹ The NASD specifically prohibits sales contests to promote the sales of ones own mutual funds according to regulation 2820(L)² which states:

The human resources department will have to work jointly with the compliance department to come up with a written policy. This policy would give guidelines on gifts and gratuity, explaining what the parameters are and what the company considers acceptable practice. They would then have to communicate this to all

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