2025-17927NoticeWallet

FINRA Triples Gift Limit: More Swag for Wall Street?

Published Date: 9/17/2025

Notice

Summary

FINRA wants to update its rule about giving gifts to employees of other companies by raising the gift limit from $100 to $300 per person each year. This change affects financial firms and their employees, making gift-giving clearer and more flexible, including special exceptions and recordkeeping rules. The SEC is now reviewing the updated plan and will decide by September 15, 2025, so businesses should watch for the final decision.

Analyzed Economic Effects

5 provisions identified: 5 benefits, 0 costs, 0 mixed.

Gift Limit Raised to $300

FINRA proposes to raise the limit on gifts given in relation to another employer’s business from $100 to $300 per person per year. The change (moved from an original $250 proposal) is intended to account for expected inflation for about 10 years.

Non-Cash Compensation Limits Also Raised

FINRA would raise the $100-per-person exceptions in its Non-Cash Compensation Rules (Rules 2310, 2320, 2341, and 5110) to $300. That means the same $300 threshold would apply when assessing whether non-cash gifts or items are excepted from prohibitions tied to sales of certain products.

Gifts to Retail Customers Exempted

Proposed Rule 3220.09 would state that FINRA Rule 3220 does not apply to gifts from a member to its own associated persons or to gifts from a member or associated person to individual retail customers. That means gifts to an individual retail customer would not be subject to Rule 3220's $300 limit or its recordkeeping requirements.

Higher Threshold for Promotional/De Minimis Items

The proposal codifies that de minimis items (like pens or notepads) and promotional items bearing a firm’s logo are not subject to the gift limit so long as their value is 'substantially below' the $300 limit. It also keeps customary commemorative items (Lucite tombstones, plaques) exempt even if they cost more than $300.

Personal, Bereavement, and Disaster Donations Exempted

The proposal would exempt customary personal gifts for infrequent life events (weddings, births), customary bereavement gifts, and donations to individuals for losses from Presidentially declared major disasters from the $300 gift limit and related recordkeeping. FINRA would codify these exceptions in proposed Rules 3220.04, 3220.05, and 3220.07.

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Key Dates

Published Date
9/17/2025

Department and Agencies

Department
Independent Agency
Agency
Securities and Exchange Commission
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