Compliance · Sponsorships
FINRA Rule 3220
Also known as: Gifts Rule, Influencing or Rewarding Employees of Others
FINRA Rule 3220 caps gifts to a customer's or counterparty's employee at $300 per person per year, up from $100 before March 2026. The limit rose from $100 to $300 in an amendment the SEC approved in February 2026, effective March 30, 2026. It covers gifts rather than the cost of ordinary business entertainment, though under Rule 3220.01 a gift handed over during a business entertainment event still counts toward the cap.
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Sponsorship and gift log
Rule 3220 caps what a firm or its people can give an employee of a customer, prospect, or counterparty, when the gift relates to that employer's business. Sponsorships, event tickets, and client-appreciation gifts all count toward the same annual total per recipient.
| Category | Treatment |
|---|---|
| Ordinary gift | Counts against the $300 annual limit, valued at cost |
| Event ticket | Valued at the higher of cost or face value |
| Personal life event gift (wedding, birth) | Excluded if customary, reasonable, and unrelated to business |
| Bereavement gift | Excluded if customary and reasonable |
| Promotional item with firm logo | Excluded if it is a promotional item of nominal value displaying the firm's logo and its value is substantially below $300 |
| Business entertainment (meals, event attendance together) | The cost of the entertainment itself is not counted toward the $300 cap, provided it is neither so frequent nor so extensive as to raise a question of propriety and is not tied to a sales target. Any gift handed over during the event is still subject to the cap under Rule 3220.01 |
Requirements
| Requirement | Detail |
|---|---|
| Annual limit | $300 per person per year, effective March 30, 2026 (previously $100) |
| Aggregation | All gifts from the firm and its associated persons to one recipient are combined toward the cap |
| Recordkeeping | Gifts must be logged and retained under SEA Rule 17a-4, except the excluded categories above |
| Supervision | Firms must have written procedures for reporting, reviewing, and recording gifts given by associated persons |
What this means for your marketing
Sponsorships count as gifts if they flow to an individual. Sponsoring a client's industry conference badge or covering an individual employee's attendance fee runs through the same $300 cap as a holiday gift. Sponsoring the event itself, paid to the organizer, is a different analysis and usually isn't a 3220 gift at all.
Log the gift before you send it, not after. Branded merchandise sent to a named contact at a client firm, tickets to a game, a bottle of wine at year-end: all of it needs to hit the firm's gift log so the annual aggregation actually works. A marketing team handing out swag without routing it through compliance is the most common way firms blow past the cap without noticing.
Separate entertainment from gifts in your event budget. Taking a client to a dinner or a game together is business entertainment, not a 3220 gift, as long as someone from the firm personally hosts them. The same ticket given without anyone from the firm present is a gift and counts toward the cap.
The $300 figure is new. Any compliance copy, gift policy page, or client-facing FAQ still citing the old $100 limit needs updating for the March 30, 2026 effective date.
The old $100 figure is stale after the 2026 amendment. Client-facing compliance copy should reflect the current number.
Even a single gift under the cap needs a record so later gifts to the same person don't push the yearly total over $300.
Paying an individual's personal attendance cost is a gift under 3220 regardless of what budget line it comes from.
Common questions
Primary sources
- FINRA Rule 3220, Influencing or Rewarding Employees of Othersfull rule text
- Regulatory Notice 26-05, FINRA Adopts Amendments to Rule 3220new $300 limit and effective date
- Gifts/Business Entertainment/Non-Cash Compensation FAQs (predates the 2026 amendment on dollar figures)FINRA staff interpretations
Related terms
Daniel Schoester
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Daniel Schoester combines years of SEO obsession with financial know-how. After receiving an Honours Bachelor of Business Administration (Finance), Daniel began working at a prominent mortgage website, where his content quickly quadrupled monthly traffic to over one million views.
Building on this success, Daniel launched Croton Content to help clients scale through evergreen content assets — notably working with Forbes Advisor, Moneywise, and Hardbacon.
In 2024, Daniel expanded his focus to YouTube after studying Google’s algorithm changes. He noticed YouTube’s increasing alignment with search visibility compared to traditional written SEO content — plus its ability to generate passive revenue and long-term brand authority.
Educational information only. This is not legal or compliance advice. Confirm current requirements with your compliance officer and the primary sources above.