Published on Feb 21, 2026 • Updated on Oct 26, 2026
This article was written by Adem Tumerkan
Content Strategist, Dunham | 2025 ThinkAdvisor Luminaries Award Winner | 2026 Wealthies Finalist, Thought Leader of the Year | Macroeconomics, markets, geopolitics & global trends
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Client gifts can be a meaningful way for financial advisors to strengthen relationships, recognize milestones, and stay top of mind. But before choosing a gift, advisors need to consider more than price and personal preference: firm policies and FINRA’s updated gift rule also matter.
FINRA Rule 3220 now permits gifts and gratuities of up to $300 per person per year, subject to applicable recordkeeping requirements and a firm’s own, potentially stricter, compliance policies. The rule applies to gifts given in connection with the business of the recipient’s employer, so advisors should confirm internal policies before purchasing or delivering a client gift.
This guide offers thoughtful client-gift ideas under $100 - a practical budget that leaves room for personalization while helping advisors stay within many firms’ internal limits. For a detailed explanation of the updated rule, including compliance considerations and recordkeeping, read Dunham’s guide to FINRA Rule 3220 and the $300 gift limit.
Whether a client enjoys cooking, travel, reading, or simple everyday comforts, the best gifts reflect that client’s interests and show that the advisor has been paying attention.
As a financial advisor, you must consider more than just budget and preferences when gifting clients - you also have compliance requirements to keep in mind.
FINRA Rule 3220 generally permits gifts and gratuities with an annual value of up to $300 per person, subject to the rule’s conditions and your firm’s policies. Firms may impose lower internal limits, require preapproval, or prohibit certain types of gifts. Before giving a client gift, confirm the current policy with your compliance team and document the gift as required.
Why does this guide still focus on gifts under $100?: Although FINRA Rule 3220’s updated $300 annual limit applies to certain business-related gifts, this guide uses a sub-$100 budget to help advisors choose thoughtful, practical gifts while leaving room for firm-specific limits, approvals, and other relationship-building expenses. Individual retail-client gifts are governed primarily by firm policy rather than Rule 3220’s $300 cap.
| Before you choose a client gift | What to know |
|---|---|
| Why are these gifts under $100? | This is a practical budget, not FINRA’s universal gift cap. A lower price point helps advisors choose quality gifts while staying within many firms’ internal policies. |
| Does FINRA’s $300 limit apply to every client gift? | No. Rule 3220’s $300 annual limit applies to covered, business-related gifts to people acting for another employer, such as institutional contacts, vendors, or counterparties. |
| What about gifts to individual retail clients? | FINRA clarifies that Rule 3220 does not apply to gifts from a member or associated person to individual retail customers; firm policies can still set limits, require approval, or prohibit specific gifts. |
| Should an advisor still check with compliance? | Yes. Confirm firm policy, obtain approval when required, and follow internal documentation procedures before giving a gift. FINRA requires firms to maintain systems for reporting, reviewing, and recording covered gifts. |
| What makes a strong client gift? | Choose a personal, useful, non-cash gift that suits the client’s interests, the occasion, and your firm’s policy—rather than simply spending up to a limit. |
One way to show sincerity to your clients is to select a gift that is personal and meaningful to that client. Here are some considerations you should make when choosing a client gift:
The bottom line, when it comes to gift giving, is to think about what matters to your client: What makes them happy? What are they interested in? When you make considerations such as these, the gifts you give become very thoughtful and meaningful to the recipients.
Here are some client gifts and the considerations made while selecting them.
Client retention is relationship-driven.
A carefully selected gift:
In an industry built on relationships, small gestures compound over time.
The best gifts are personal. If you’re not sure of your client’s preferences, a handwritten note and careful packaging add a meaningful touch. If possible, deliver the gift personally - it makes a lasting impression.
You’ve heard it said, “It’s the thought that counts,” and that couldn’t be truer here. Clients may not remember the most expensive gift, but they will remember the most thoughtful one. Following these guidelines and adhering to compliance rules, you can make this holiday season a memorable one for your clients - and set your firm apart in the process.
Also, don’t forget to document client gifts according to your firm’s policies to stay compliant.
What is the FINRA gift limit for financial advisors? FINRA Rule 3220 generally limits gifts tied to the recipient’s employer’s business to $300 per person per year. The rule does not apply to gifts to individual retail clients, but your firm may still set limits for those gifts. Check your firm’s policy before making a purchase.
Do financial advisors need to track and document client gifts? Yes, when required by FINRA rules or firm policy. FINRA member firms must keep records of covered business gifts and count gifts from everyone at the firm toward each recipient’s annual limit. Retail client gifts fall outside Rule 3220, but your firm may still require you to report them.
Can financial advisors give clients cash or gift cards? Gift cards may be an option, but check your firm’s policy before giving cash or cash equivalents. Firms may have added restrictions or approval requirements. A gift card should go through the same compliance review as any other gift, including checks on the recipient and any applicable annual limit.
What are some thoughtful client gifts for financial advisors? Thoughtful options include books, quality drinkware, food gifts, plants, or items tied to a client’s hobbies. Choose something that reflects what you know about the person rather than spending up to a limit. Before buying, check your firm’s gift policy, approval rules, and any other gifts already given to that recipient.
This communication is general in nature and provided for educational and informational purposes only. It should not be considered or relied upon as legal, tax, or investment advice or an investment recommendation, or as a substitute for legal counsel. Any investment products or services named herein are for illustrative purposes only and should not be considered an offer to buy or sell, or an investment recommendation for, any specific security, strategy, or investment product or service. Always consult a qualified professional or your own independent financial professional for personalized advice or investment recommendations tailored to your specific goals, individual situation, and risk tolerance.
Dunham & Associates Investment Counsel, Inc. is a Registered Investment Adviser and Broker/Dealer. Member FINRA/SIPC. Advisory services and securities offered through Dunham & Associates Investment Counsel, Inc.
