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🤝 Employee Conduct & Reportable Events · Lesson 3 of 5 · 6 min

Gifts, Dinners and Campaign Checks

🎁 For decades the answer to 'how much can I give?' was $100. In 2026 it changed. Here is the number that applies now.

💡 Key idea

Gifts: $300 per person per year since March 30, 2026 (was $100). Entertainment with the rep present is not a gift. G-37: $250 per election if you can vote, or a 2-year ban.

🧠 Why it matters

FINRA RULE 3220 limits gifts to an EMPLOYEE OF ANOTHER FIRM (or other person) in relation to that employer's business to $300 PER PERSON PER YEAR. The limit was $100 until FINRA raised it, effective March 30, 2026 (Regulatory Notice 26-05). The same $300 applies to non-cash compensation rules, and MSRB Rule G-20 matched it for FINRA-member dealers from June 1, 2026. Gifts are valued at cost (tickets at the higher of cost or face value) and recorded; nominal logo items and personal gifts are excluded. BUSINESS ENTERTAINMENT, where the rep attends (dinner, a game), is not a gift if not excessive. MSRB G-37: a municipal finance professional may give up to $250 PER ELECTION to a candidate they can VOTE for; above that, the firm is banned from municipal business with that issuer for TWO YEARS.

📈 In the real world

🏟️ Jamal gives a fund wholesaler's contact a $250 bottle of wine in March, then takes him to a ballgame in June and sits with him. The wine counts toward the $300 annual limit; the ballgame with Jamal present is business entertainment, judged by reasonableness, not the cap. Another $100 gift in December would push past $300.

📌 Takeaways

  • FINRA 3220 and MSRB G-20: $300 per person per year (was $100 before 2026)
  • Entertainment with the rep present is not a gift, but must not be excessive
  • G-37: $250 per election when entitled to vote; otherwise a two-year business ban

📖 Terms in this lesson

Gift limit (Rule 3220): FINRA's limit on gifts to someone at another firm, related to business: $300 per person per year since March 30, 2026.

MSRB Rule G-37: The MSRB pay-to-play rule: a contribution to an issuer official triggers a two-year business ban unless the giver can vote for the official and gives at most $250 per election.

✅ Test yourself

As of November 2026, what is the FINRA Rule 3220 gift limit?
  1. $250 per person per election
  2. $500 per person per year
  3. $300 per person per year
  4. $100 per person per year

Answer: C · $300 per person per year

FINRA raised the limit from $100 to $300 per person per year effective March 30, 2026 (Regulatory Notice 26-05). $250 per election is MSRB G-37's political contribution de minimis.

A municipal finance professional gives $400 to a mayoral candidate she can vote for, and the candidate wins. What is the consequence under MSRB G-37?
  1. Her firm must disclose it on Form U4
  2. She must ask the mayor for a refund
  3. Her firm faces a two-year ban on municipal business with the city
  4. None, because she lives in the city

Answer: C · Her firm faces a two-year ban on municipal business with the city

The de minimis is $250 per election for a candidate the person can vote for. $400 exceeds it, triggering a two-year ban on municipal securities business with that issuer. Being a voter does not excuse the excess.

A rep takes a fund company's sales manager to dinner and joins him. How is this treated under FINRA's gift rule?
  1. As a $300 gift, whatever its cost
  2. As a political contribution under G-37
  3. As non-cash compensation needing FINRA approval
  4. As business entertainment, not a gift

Answer: D · As business entertainment, not a gift

When the rep attends, a meal is business entertainment, which must be reasonable and not excessive but does not count toward the gift limit. It has nothing to do with G-37.

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