UPDATE 1: FINRA Raises Gift Limit to $300 — Effective March 30, 2026
Summary: FINRA has amended Rule 3220 to increase the gift limit from $100 to $300 per person per year, effective March 30, 2026. The rule also now formally codifies guidance on how to value, aggregate, and document gifts — including specific rules for event tickets, personal gifts, and promotional items.
What This Means for You: If your firm gives any gifts to employees of other firms — including clients at institutional accounts, vendors, or counterparties — your compliance policy needs to be updated before March 30. The new $300 limit applies per recipient per year and requires aggregation across all gifts from all staff members. Note that the rule does not apply to gifts to your own employees or to individual retail clients. Tickets to events must be valued at the higher of cost or face value — not what you actually paid on a secondary market.
Action Required?
∙ Update your written gifts and entertainment policy to reflect the new $300 limit before March 30
∙ Confirm your aggregation tracking system captures all gifts across all staff members to a single recipient
∙ Brief your team on the new rules — particularly on ticket valuation and the personal gift exemption
Urgency: HIGH — Effective date is March 30, 2026. Less than 3 weeks away.
Bottom Line: Update your gifts policy now — the deadline is March 30 and the new rules come with specific documentation requirements.
UPDATE 2: What SEC Examiners Actually Look For at Newly Registered RIAs
Summary: The SEC’s Division of Examinations published findings from its examinations of newly registered investment advisers, identifying the most common compliance failures found during early-stage RIA exams. The three primary problem areas were compliance policies and procedures, disclosure documents, and marketing materials.
What This Means for You: If you registered within the last three years you are a priority exam target — the SEC has explicitly stated it examines newly registered advisers within a reasonable period after registration. The most common finding was advisers using off-the-shelf compliance manuals that were never tailored to their actual business. Examiners also found inaccurate Form ADV filings — particularly around fees, conflicts of interest, and services offered — and marketing materials that couldn’t be substantiated. Your CCO being stretched too thin was also flagged as a red flag.
Action Required?
∙ Pull your compliance manual and confirm every policy actually reflects how your firm operates — generic language is a red flag
∙ Review your Form ADV Part 2A for accuracy on fees, conflicts, AUM, and services — annual amendment is due March 31
∙ Make sure any performance figures or credential claims in your marketing can be documented and substantiated
Urgency: MEDIUM — No single deadline but newly registered RIAs are actively being prioritized for examination in 2026.
Bottom Line: If your compliance manual still has another firm’s name in it somewhere, fix that before an examiner shows up.
Compliance Calendar — March 2026
∙ March 30 — FINRA Gifts Rule new $300 limit takes effect
∙ March 31 — Form ADV annual amendment due for most RIAs
∙ June 3 — Regulation S-P amended rule compliance deadline
ClearReg is an independent research and information service. This briefing is for informational purposes only and does not constitute legal, compliance, or investment advice. Always consult a qualified compliance professional or attorney for guidance specific to your firm.
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