ADISA recently submitted comments to FINRA’s office of the corporate secretary in response to FINRA’s Regulatory Notice 18-08, which seeks comments on proposed Rule 3290, which would replace current FINRA Rule 3270 (Outside Business Activities of Registered Persons) and FINRA Rule 3280 (Private Securities Transactions of Associated Persons).

ADISA surveyed members who are broker-dealers, investment advisers and others, regarding FINRA’s proposed new rule on outside business activities, and found that our membership is strongly in favor of adopting the Proposed Rule and rescinding FINRA Rules 3270 and 3280. Furthermore, our membership believes that simplifying the oversight responsibilities of broker-dealers provides relief that outweighs any possible benefits that might otherwise flow from that oversight.

ADISA also suggested qualifying the word “public” in the Proposed Rule, so as to define it more precisely to avoid potential misuse.

The comment letter was drafted by ADISA Legislative & Regulatory Committee Chair Catherine Bowman (The Bowman Law Firm), ADISA Immediate-Past President John Grady (DLA Piper), and ADISA Executive Director John Harrison. The letter was signed by current ADISA President Keith Lampi (Inland Private Capital Corporation).

You can read the letter in its entirety here.