Lots of advisers track the FINRA gift limit of $100. Some specifically because they have dual registration. More use that limit because it became a de facto industry standard because it was the only one out there.
The current gift limit of $100 has been in place since 1992. That was way too low. FINRA had proposed an increase to $250. Commenters asked for a higher number and in response FINRA bumped it to $300 per year. That is now going forward with a few twists to think about.
There is an exclusion for personal gifts, de minimis items and promotional/commemorative gifts. Personal gifts require some kind of pre-existing relationship and can’t be paid for or reimbursed by the firm. De minimis items are excluded just to make record-keeping easier. Nobody wants to count pens. Decorative items with no utility may cost a lot but don’t provide much utility.
You also need to define a year. You get to decide calendar year, fiscal year or rolling year.
Sources:
- Order Approving a Proposed Rule Change, as Modified by Amendment No. 1, To Amend FINRA Rule 3220 (Influencing or Rewarding Employees of Others) Februrary 12, 2026
- Finra to Raise Gift Limit to $300 by Miriam Rozen in AdvisorHub
- FINRA Revises Gifts Rule: Key Changes and Compliance Considerations by Keith Kessel