Compliance · 8 min read · Updated September 2026
The $300 FINRA gift limit doesn't apply to your clients. Here's what does.
Most advisors think the new rule raised what they can spend on client gifts. It didn't. Here's the number that actually governs it.
The Financial Industry Regulatory Authority raised its gift limit from $100 to $300 for the first time since 1992, effective March 30, 2026. You've seen the headline. You probably haven't seen the correction.
Rule 3220 caps gifts given "in relation to the business" of the recipient's employer — that means gifts between industry professionals, not what you send a retail client for their birthday or the holidays. So why does every advisor assume it does? Because for over thirty years, most broker-dealers built their internal client-gift policy around that same $100 number anyway.
"I can spend $300 on client gifts now."
Rule 3220 doesn't set that number for retail clients at all.
"My firm's internal policy sets my real number."
That's what always governed client gifts, FINRA figure or not.
What Rule 3220 actually covers
A few mechanics, for context: gifts to employees of other firms, institutional clients, vendors, or counterparties, where the gift could influence a business decision made on someone else's behalf — not gifts to your own retail clients. Gifts are valued at cost, not retail price, and taxes and delivery don't count. Event tickets are valued at whichever is higher: cost or face value. All gifts from your firm and its associated persons to one recipient are combined for the year. Personal gifts for life events, bereavement gifts, logo'd promotional items, deal-closing mementos, and disaster relief donations don't count toward the cap. See FINRA Rule 3220 for the full text.
First change to the FINRA gift limit since 1992 — and it applies to gifts between industry professionals, not advisor-to-client gifts.
So what actually limits your client gifts?
Your firm's written supervisory procedures. Full stop. Many broker-dealers adopted $100 as their internal client-gift ceiling because it matched the old FINRA number, even though FINRA never required that specific number for retail clients. That policy is enforceable against you as a condition of your registration — violate it and you can face disciplinary action, a note on your Form U5, or a supervisory failure finding against your firm. As of this writing, no broker-dealer has publicly confirmed raising that internal number to $300.
1. What is our internal client-gift limit?
2. Has it changed since March 30, 2026?
Limits that don't depend on your firm
Even once you know your firm's number, a few other rules can cap you lower, and these apply no matter what your firm's policy says:
ERISA — service providers
State insurance anti-rebating laws
You know the limits. Here's what advisors ask us next.
Does the FINRA $300 gift limit apply to gifts I give my own clients?
No. FINRA Rule 3220 covers gifts given in connection with someone else's employer's business, meaning gifts between industry professionals. It does not set a number for gifts to your own retail clients.
Then why do so many advisors think it does?
Most broker-dealers adopted the old $100 FINRA figure as their own internal client-gift policy, even though FINRA never required that number for retail clients. The firm policy and the FINRA rule got conflated over time.
What actually limits what I can spend on a client gift?
Your firm's written supervisory procedures. Check with your compliance department for your firm's actual internal limit, and don't assume it matches FINRA's new $300 figure until they confirm it.
Has any brokerage confirmed raising its internal limit to $300?
Not publicly, as of this writing. The rule took effect March 30, 2026, and firms typically update internal policy without a public announcement.
Are there other limits I need to watch regardless of my firm's policy?
Yes. ERISA caps gifts to retirement plan fiduciaries at $250 and to service providers at $100. State insurance anti-rebating rules can be lower still. Labor union rules cap at $250.
Make your real limit count
Most advisors gift on two occasions: In December as a holiday gift, and immediately after a client signs a big account. That's not wrong. It's just less impactful. A gift immediately after signing feels like a bribe for handing their hard earned assets to you and a holiday gift just gets lost in the noise of all the other gifts they receive during the traditional gifting season. Just moving your onboarding gift back 90days from the client signing grows the impact since it gives the relationship time to settle after the headache of rollovers and paperwork and is in the prime period where you are gaining their trust which opens the doors to referrals. Likewise moving a yearly gift to Thanksgiving (since you're thankful for their business) or their anniversary helps you stand out from the crowd.
And the gifting problems usually shows up in the gift itself. When gifting at scale most advisors turn to what will be easiest to coordinate, so the standard becomes a gift basket, a bottle of wine, a gift card, or low value swag. The problem is the basket or a bottle of wine gets opened, used up, and gone within a week, and once it's gone, so is the reminder of who sent it.
So, what's the alternative? You need a gift that checks the following 5 boxes:
Give a gift that stands out. Generic branded swag blends into a drawer full of other vendors' branded swag. A gift built around the client — their name, their initials, something chosen for them specifically — doesn't.
Make it personal, not promotional. A pen with your logo on it is an ad. A gift engraved with "Made Especially for The Jones Family" makes them feel special. Clients feel the difference immediately, and it changes how they feel about the firm that sent it.
Give something that lasts. Consumables disappear in a week. A durable, well-made gift means the reminder of who sent it lasts for years or decades.
Give something they'll actually use. A gift that gets used regularly earns a permanent spot in a client's home. One that gets set aside "for good" or forgotten in a closet earns nothing. Usefulness is what turns a gift into repeated exposure, especially if it's used where your client's friends and family congregate that can spark a conversation. That's a referral conversation your firm didn't have to start.
Make it exciting. Clients don't need an expensive gift to get genuinely excited especially if they are a high net worth client, but they need one that feels chosen for them. That doesn't mean you need a different gift for every client, but your gift doesn need to be something out of the norm and the personalization goes a long way to boosting the excitement.
Raising your internal limit gives you more room to work with. It doesn't fix a generic gift, and it doesn't make a consumable one last past the week it arrives. Before you spend the extra $200, spend it on something that sticks around.
Why advisors choose Retention Gifts
Raising your limit only pays off if what you send with it actually works. Here's how our programs are built to make sure it does.
Engraved, personalized Cutco pieces that stand out, feel personal, last for decades, get used every day, and spark a real reaction due to their quality — not just one of the five, all of them.
Deductible, not just impactful.
Client gifts typically qualify as a deductible business expense under current IRS $25 rule, so raising your limit buys more impact without changing what it costs you after taxes.
Client dates, engraving, and delivery are set up once and handled automatically from there. A better gift program doesn't mean more work on your plate.
Get a better ROI on your client appreciation
Whatever number your firm lands on, spend it on something clients remember. Compliant, documented, personalized client gifts built for exactly this — from engraved Cutco to gifting programs you can run across your whole book.
This article is for general information only and is not legal, compliance, or tax advice. Retention Gifts is not affiliated with or endorsed by FINRA and is not a CPA firm. Confirm your firm's specific gift policy with your compliance department and consult your own CPA or tax advisor before making decisions based on this information.
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