MasterCompliance continues to provide clients and the public with guidance on industry focus areas, new rules, compliance foundations, and regulatory priorities. This blog explores our top 5 blogs of 2020.
An outside business activity (“OBA”) is defined as a registered person having any business activity outside the scope of the relationship with their member firm. As defined in FINRA Rule 3270, this may include acting as an employee, independent contractor, sole proprietor, officer, director, or partner for any other entities besides the member firm. Generally, the activity may also involve compensation or a reasonable expectation of compensation.
FINRA initiated a retrospective review of the annual compliance meeting (“ACM”) requirement in April 2018. The findings were published on October 18, 2019 in FINRA Regulatory Notice 19-34. Although the final assessment indicates that they are determined to maintain the ACM requirement without change, the Notice did provide additional guidance on fulfilling the requirements.