MSRB Tweaks Gift Rules to Sync with Broker Standards
Published Date: 5/7/2026
Notice
Summary
Starting May 1, 2026, brokers, dealers, and municipal advisors need to follow updated rules about gifts and freebies to match new FINRA standards. The Municipal Securities Rulemaking Board cleaned up the language and made the rules clearer, so everyone’s on the same page. These changes don’t cost money but keep things fair and transparent in the municipal securities world.
Analyzed Economic Effects
8 provisions identified: 6 benefits, 0 costs, 2 mixed.
New Supervision and Recordkeeping Rules
Firms must have supervisory systems and procedures reasonably designed to ensure gifts and gratuities are reported to the firm, reviewed for compliance, and maintained in firm records; procedures must ensure the person giving a gift is not the same person determining whether the gift relates to the recipient's employer. However, personal gifts, bereavement gifts, de minimis/promotional/commemorative items, and donations tied to federally declared major disasters are not subject to the recordkeeping requirement.
Gift Limit Raised to $300
If you are a broker, dealer, or municipal advisor subject to MSRB Rule G-20, the dollar gift limit is increased from $100 to $300 per person per year. The change also raises the related non-cash compensation limit in MSRB Rule G-20(g)(i) from $100 to $300.
Different Compliance Dates for Firms
The MSRB's amendments are operative June 1, 2026 for dealers that are FINRA members, but municipal advisors and dealers that are not FINRA members (bank dealers) have a separate compliance date of December 1, 2026. The MSRB filed the proposed rule change on May 1, 2026.
Value Gifts at Cost (Except Tickets)
Under the amended rule, gifts (other than tickets to sporting or other events) must be valued at cost excluding tax and delivery charges; tickets must be valued at the higher of cost or face value. If a gift is given to multiple recipients, firms must record each recipient's name and calculate the value on a pro rata per-recipient basis.
Aggregation Rule and Procedure Requirement
Firms must aggregate all gifts given by the firm and each associated person to a particular recipient over the course of a year and must state in their procedures whether aggregation is on a calendar year, fiscal year, or rolling basis beginning with the first gift. The aggregation requirement does not apply to gifts that meet specified exceptions.
Business Entertainment Gifts Are Counted
The amended rule explicitly states that gifts given during normal business dealings or business entertainment are subject to the $300 gift limit and recordkeeping requirements unless they qualify as personal gifts, de minimis gifts, promotional/commemorative items, or other listed exceptions.
Certain Gifts Explicitly Exempted
The amended rule codifies that transaction-commemorative items, de minimis items (substantially below the $300 limit), promotional items of nominal value, reasonable and customary bereavement gifts, personal gifts for infrequent life events, and donations to assist individuals in federally declared major disasters are not subject to the $300 gift limit and, in many cases, not subject to recordkeeping.
Rule Doesn’t Apply to Gifts to Your Own Staff or Retail Customers
The MSRB clarifies that MSRB Rule G-20 does not apply to gifts given by a regulated entity to its own employees or partners, and the amendments add Supplementary Material mirroring FINRA stating the rule does not apply to gifts from a member to its own associated persons or to gifts to individual retail customers.
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