FINRA's Gift Limit Is Now $300: What Advisors Need to Know Before Year-End Client Gifts
FINRA's gift limit is now $300 per person per year, up from $100. The change to Rule 3220 took effect March 30, 2026, the first increase since 1992 (FINRA Regulatory Notice 26-05).
That makes this the first holiday season under the new limit. And plenty of advisor-marketing guides still say $100.
The higher number helps. But it doesn't change who the rule covers, what counts toward it, or the other limits that may apply. That's where year-end gifting gets complicated.
This article is general information, not legal or compliance advice. Confirm gift limits and approvals with your firm's compliance team.
We'll cover:
- What counts toward the $300, and what doesn't
- Three kinds of gifts the limit doesn't cover
- Who the rule actually covers (and why retail clients are different)
- RIAs, referral-related gifts, and the lower limits that may still apply
- What a useful gift log contains
- A three-tier year-end plan, priced before shipping and tax
The new FINRA gift rule at a glance
| Before March 30, 2026 | Now | |
|---|---|---|
| Annual limit per recipient | $100 | $300 |
| How it's counted | Interpretive guidance (NTM 06-69) | Codified: all gifts from the firm and every associated person to one recipient, aggregated over the year |
| How gifts are valued | Guidance | At cost, excluding tax and delivery charges |
| Who it covers | People receiving gifts in relation to their employer's business | Same. Gifts to individual retail customers are outside the rule |
| Conforming rules | $100 | $300 in Rules 2310, 2320, 2341 and 5110 |
Sources: FINRA RN 26-05, FINRA Rule 3220, Morgan Lewis.
The $300 counts the gift, not the shipping
Gifts are valued at cost, exclusive of tax and delivery charges (Rule 3220, Supplementary Material .02). Shipping and sales tax don't count. Everything you paid for as the gift does: the contents, the box, the card, any customization. Tickets to sporting or other events are the exception: they're valued at the higher of cost or face value.
Two details trip people up.
It's per recipient, across the whole firm. If your branch sends a CPA a $200 gift box and a colleague in another office gives the same CPA a $150 pair of tickets, both count toward one $300 for that year (.03). Personal life-event gifts, de minimis and logo promotional items, and commemorative items are left out of the total. Your firm decides whether "year" means calendar, fiscal or rolling, and documents it.
A logo on the card doesn't make it a promotional item. Rule 3220 excludes de minimis items and promotional items of nominal value with the firm's logo. Our read is that a gift box with your logo on the enclosure card is still a gift and counts in full. Ask your compliance team how they treat it rather than assuming the exclusion.
The old NTM 06-69 guidance is superseded, so if your gift policy still cites it, it's due for a refresh.
Gifts the $300 doesn't cover
Three kinds of gifts sit outside the limit (Rule 3220, Supplementary Material .01, .04, .05):
- Sympathy gifts. Customary and reasonable bereavement gifts aren't considered to be in relation to the recipient's employer's business.
- Personal life events. A wedding gift or a gift for a new baby isn't subject to the limit. But when the firm pays for it, directly or by reimbursing an advisor, FINRA presumes it isn't personal.
- Business entertainment. Taking a contact to dinner or a game isn't a gift under the rule. A gift handed over during that event is.
Your firm may still want these logged, so check the policy before you skip the record.
Your retail clients aren't subject to FINRA's $300 limit
They follow your firm's own gift policy instead. This is the part most summaries skip. Rule 3220 covers gifts given in relation to the business of the recipient's employer. FINRA states plainly that it "does not apply to gifts from a member or an associated person to individual retail customers" (Rule 3220, Supplementary Material .09).
In practice:
- Under the $300 cap: CPAs, estate attorneys, HR and benefits staff at a plan sponsor, employees of institutional clients, and other centers of influence.
- Governed by your firm's policy: the retail households you serve.
Many firms apply a similar number to retail clients anyway. That's a firm decision, and it's the one to check first.
RIAs have no federal dollar cap
The Advisers Act doesn't set a gift limit. Each RIA's code of ethics does. If you're dually registered, though, Rule 3220 still applies to gifts you give business contacts on the broker-dealer side. Check both before you set a budget.
Be careful with gifts tied to referrals
For RIAs, a gift tied to a referral, testimonial or endorsement can raise a different set of compliance requirements under the SEC Marketing Rule. Compensated testimonials and endorsements may require disclosures and adviser oversight, with additional requirements depending on the arrangement and the amount of compensation.
The practical takeaway for year-end gifting is simple: don't assume a referral-related gift is treated the same way as an ordinary holiday gift. If you're sending something specifically because someone referred business, run it through compliance first.
A practical gift log has five fields
Firms must have gifts reported, reviewed and recorded (Rule 3220, Supplementary Material .08); your compliance team sets exactly how. A practical gift log can be very simple. We recommend five fields:
- Recipient (full name)
- Firm (where they work, which is how you know whether 3220 applies)
- Date (ship or delivery date)
- Gift (what was sent)
- Value (cost, excluding shipping and tax)
Add a column marking each name as a retail client or a business contact. Your reviewers can split the list in one pass.
Six recipients need a second look
The $300 is the ceiling for FINRA. Several other rules sit lower, and some sit near zero (Morgan Lewis).
| Recipient | Why it's different |
|---|---|
| Union officials and trustees of union-affiliated plans | Gifts above $250 per official per fiscal year can trigger Form LM-10 reporting (DOL OLMS) |
| ERISA plan fiduciaries (benefits staff at a plan sponsor you service) | DOL treats gifts under $250 a year as insubstantial; there's no statutory safe harbor (Morgan Lewis) |
| Federal employees | Generally limited to gifts of $20 or less per occasion and $50 per year from any one source (5 CFR 2635.204) |
| State and local officials, public pension staff | State and local ethics law governs, often far below $300. Minnesota, for example, bars state and University of Minnesota employees involved in purchasing from accepting "a rebate, gift, money, or anything of value other than items of nominal value" from current or potential contractors (Minn. Stat. 15.43, subd. 1). If you manage or seek public-entity assets, SEC Rule 206(4)-5 (pay-to-play) also applies; it governs political contributions rather than gifts, so loop in compliance |
| Municipal securities contacts, bank dealers | MSRB Rule G-20 matched the $300, but bank dealers and non-FINRA municipal advisors remain under the legacy $100 limit until December 1, 2026, unless they elect early compliance with the amended rule (MSRB) |
| Anyone tied to a pending decision | A gift timed to a mandate, contract or vote reads as influence at any value |
If any of these names are on your list, route them to compliance before anything ships.
A year-end plan in three tiers
Most firms don't need 40 different gifts. They need three, one per tier, so every name on a tier carries the same known value. All prices below are before shipping and tax, from our wealth management lookbook.
| Tier | Gift value | Use | What it looks like |
|---|---|---|---|
| Broad list | $34 to $50 | A consistent gift for a larger client or relationship list | A candle, cookies and tea opened the same evening; a six-tea flight that gets finished one quiet night at a time |
| Priority relationships | $105 to $170 | Longtime clients, milestones, and relationships where you want something more substantial | Le Creuset mug and mini cocotte with espresso; a full weekend breakfast with a tumbler and spatulas that stay in the kitchen |
| Signature gifts | $168 to $249 | A small number of relationships where the gift should feel memorable | A Flamingo Estate candle, soap and body wash set used every morning until spring; a keepsake crate with room for a book you'd recommend |
Sweater Weather Bento · $34
Good Morning Deluxe · $148
Quiet Hour · $175
Why top out at $249 when the cap is $300? Because the cap is annual and firm-wide. A $249 gift leaves room for a second gift later in the year, a retirement or a milestone, without anyone having to recalculate. A $295 gift doesn't.
The other rule we'd hold to: pick gifts that get used. A client who brews the coffee on the first cold morning remembers who sent it.
The easiest way to run the list
For most advisory firms, the hard part isn't choosing a gift. It's getting 75 or 250 gifts approved, addressed, documented and out the door without turning it into a December project.
That's what we've designed our wealth management gifting process around.
Send us one spreadsheet with your recipients, addresses and tiers. We'll match each tier to the gift you chose, print your note on a card with your logo, ship each package on your timeline, and return an itemized record of what was sent and its value. Every gift is priced below $300 before shipping and tax, and every gift is hand-packed and inspected by our team in Minnesota. Where a gift lands against each recipient's annual total is your compliance team's call.
You get one list back for your records. Your compliance team still makes the final call on what's permitted.
Year-end lists are best placed by mid-November.
Client Gifts for Wealth Management, 2026
Three tiers, sample notecards, and how the list works.
Already have a list? Send it over and we'll match a gift to each tier.
FAQ
What is the FINRA gift limit in 2026? $300 per person per year, effective March 30, 2026, under amended FINRA Rule 3220 (RN 26-05). It replaced the $100 limit set in 1992.
Does shipping count toward the $300? No. Gifts are valued at cost, excluding tax and delivery charges. The gift's contents, packaging and card count.
Does the $300 limit apply to gifts for retail clients? No. Rule 3220 doesn't apply to gifts to individual retail customers. Those follow your firm's own gift policy, which may set its own limit.
Do RIAs have a gift limit? Not a federal one. Each RIA's code of ethics sets it. Dually registered advisors also follow Rule 3220 for business-contact gifts.
Do sympathy gifts count toward the $300? No. Customary and reasonable bereavement gifts aren't considered to be in relation to the recipient's employer's business (Rule 3220, Supplementary Material .05). Your firm may still ask you to log them.
Can I send a client a gift for referring someone? Check with compliance first. For RIAs, a gift tied to a referral, testimonial or endorsement can fall under the SEC Marketing Rule's requirements for compensated testimonials and endorsements, which may include disclosure and oversight. Don't assume it's treated like an ordinary holiday gift.
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