Final answer:
Lilly Bordan's email flyer to her 150 clients would be classified as retail communications by FINRA, as it exceeds the threshold of 25 retail investors in a 30-day period and promotes a seminar discussing investments.
Step-by-step explanation:
The communications created by Lilly Bordan, a registered representative who e-mailed a flyer to her clients, would typically be classified by the Financial Industry Regulatory Authority (FINRA) as retail communications. That is because retail communication is any written correspondence, including electronic communication, that is distributed or made available to more than 25 retail investors within any 30 calendar-day period. In this instance, since Lilly sent the flyer to all 150 of her clients, it exceeds the 25 retail investor threshold and hence, falls under this category. Retail communications are subject to FINRA rules that require a firrm's communications with the public to be based on principles of fair dealing and good faith, guided by a consideration of all relevant information, including the potential benefits and risks associated with the investment product or service being advertised. Notices or communications that promote upcoming seminars where investments will be discussed fall firmly under these requirements and require review and approval by a principal of the firm before use.