The rule changed in March 2026, and most of the internet hasn’t caught up
If you search for the FINRA gift limit, you’ll mostly find articles saying $100. That number is out of date.
On February 12, 2026, the SEC approved an amendment to FINRA Rule 3220 raising the annual gift limit from $100 to $300 per person per year. The amended rule took effect March 30, 2026. The $100 figure had stood since 1992, which is why the adjustment was so large — inflation had quietly eaten most of it.
There’s a second point that matters more for birthday cards, and it’s the one advisors most often get wrong.
Rule 3220 probably doesn’t apply to your retail clients at all
Rule 3220 governs gifts given “in relation to the business of the employer of the recipient.” It’s aimed at situations where you might improperly influence someone who owes a duty to their own employer — an institutional counterparty, a plan sponsor’s staff, a gatekeeper.
It does not apply to gifts to a member firm’s own retail customers.
So a birthday card to Mrs. Alvarez, your individual client of eleven years, sits outside the Gifts Rule’s scope. The $300 limit isn’t the constraint people assume it is, because for most advisor-client birthday mailings the rule was never the operative one.
That said, three things still apply:
Your firm’s own policy. Broker-dealers and RIAs routinely set internal limits below FINRA’s, sometimes well below, along with pre-approval and logging requirements. Your compliance manual governs you regardless of what the rule permits.
Recordkeeping where the rule does apply. For covered gifts, firms must maintain systems and records, and review by someone other than the person giving the gift.
Other regimes. MSRB Rule G-20 is being aligned to $300, but municipal advisors and bank dealers stayed at $100 until December 1, 2026. Retirement plan work brings ERISA considerations. State insurance rules have their own limits.
Where a $5 card sits
Nowhere near any of it.
The de minimis carve-out in the amended rule exempts gifts of nominal value — the examples given are pens, notepads, modest desk ornaments — provided the value is substantially below the $300 limit. A greeting card is comfortably in that territory, and for retail clients you’re outside the rule’s scope to begin with.
The practical read: a birthday card is the least complicated thing an advisor can send. Not the most impressive. The least complicated. That’s its whole appeal in a compliance-heavy business.
Contrast that with what advisors more commonly send:
| Gesture | Compliance friction |
|---|---|
| Birthday card | Minimal. Nominal value, non-cash, no offer attached. |
| Bottle of wine | Value-dependent, alcohol policies, some firms prohibit outright. |
| Steak dinner | Business entertainment rules, separate treatment, attendance requirements. |
| Gift basket, $75 | Under the limit, but logged, approved, and tracked. |
| Sporting event tickets | Entertainment vs gift distinction, and the answer depends on whether you attend. |
| Cash or gift card | Never a good idea. Cash equivalents draw scrutiny in every direction. |
The actual argument for doing it
Compliance explains why you can. It doesn’t explain why you’d bother.
The case is specific to this profession: your product is invisible. A client can’t see the rebalancing, the tax-loss harvesting, or the three hours you spent on their estate documents. What they experience is quarterly statements and market noise they don’t control. In a good year they credit the market. In a bad year they wonder what they’re paying for.
Advisory relationships don’t usually end over performance. They end over silence — the client who felt like an account number, drifted, and moved when a brother-in-law recommended someone.
A birthday card is a touch that isn’t about money. It’s the only piece of mail you send that doesn’t contain a number. That’s precisely what makes it land.
It also arrives at a moment when people take stock. Birthdays make people think about retirement, about their kids, about time. An advisor who is present in that week, without asking for anything, is positioned differently from one who appears at annual review time.
What to send, and what not to
Do: a real card, mailed to the home, with the client’s name on it and a short handwritten-feeling message. Your firm’s return address. Signed by you.
Don’t include an offer. No “let’s review your allocation,” no referral request, no seminar invitation. The moment a card carries a pitch, the client reads the whole gesture as a pitch — and depending on content and your firm’s policy, it may become a communication with the public subject to review and approval requirements. Keep it a card.
Don’t reference their portfolio. “Hope this year is as good as your returns were” is a joke that ages badly in a drawdown.
Don’t send to prospects. A birthday card to someone who isn’t a client yet is unsettling — it says you have their date of birth. Clients only.
One line is enough: “Happy birthday, Dan. Glad to be working with you. — Ray”
The economics
Advisor client lists are small relative to other professions, which makes this unusually cheap.
| Book size | Annual cost at $5/client |
|---|---|
| 75 households | $375 |
| 150 households | $750 |
| 300 households | $1,500 |
Against a book generating well into six figures of revenue, and where a single retained household is worth thousands a year in fees, the math isn’t close. This is one of the few client-appreciation line items where the cost is genuinely immaterial.
Two operational notes specific to advisors:
Send to the household, not both spouses separately — unless you know both dates, in which case two cards is correct and noticing the less-engaged spouse’s birthday is worth more than noticing the primary contact’s.
Your CRM already has this. Redtail, Wealthbox, Salesforce Financial Services Cloud — birthdays are usually a standard field. The list is a five-minute export, not a data collection project.
Where Delivered Cards fits
You upload one spreadsheet with names, birthdays, and addresses. We print and mail a real card ahead of each birthday, every year, for $5 per person — card, printing, envelope, and USPS postage included, with your firm’s return address on the envelope. It renews annually.
There is no field for year of birth anywhere in the system. For an audience sensitive to what data vendors hold, that’s worth knowing.
Where we’re not a fit:
- No printed signature or firm logo. Your return address goes on the envelope, but we don’t reproduce a signature block or brand the card. Competitors built for advisors do this; we don’t.
- No CRM integration. Not Redtail, not Wealthbox, not Salesforce. You export a spreadsheet.
- No gift add-ons. Some advisor-focused card services attach chocolates or gift cards at higher price tiers. We mail a card. That’s it.
- No compliance archive. If your firm requires retained copies of client communications, you’ll need to handle that yourself.
- US addresses only, and birthdays only — no holiday or condolence cards.
If you need branding and an audit trail, an advisor-specific vendor is the better call. If you want the simplest possible version at the lowest flat price, this is it.
See how it works → · Upload your list →
We’ve also written about client and customer birthday cards more broadly, why a physical card still lands, and how automated card services compare.
General information, not compliance or legal advice. FINRA rules, MSRB rules, state insurance regulations, and your firm’s own policies all interact. Confirm anything client-facing with your compliance department before acting. Rule details verified August 2026.