Client Alert Update: FINRA Sets Effective Date for New Rule 3290 (Outside Activities Requirement)

On October 19, 2026, we wrote a Client Alert on the SEC’s approval of FINRA Rule 3290 (Outside Activities Requirements) and the framework of the new rule. As an update to that alert, on October 26, 2026, FINRA announced in Regulatory Notice 26-20 that new Rule 3290 will take effect on October 25, 2027. As part of the FINRA Forward initiative, the new rule consolidates Rules 3270 and 3280 to create a single framework for investment-related outside activities and securities transactions, eliminating rule-based reporting and review requirements for non-investment-related activities. The regulatory notice highlights exclusions, stating that Rule 3290 does not apply to member or affiliate activity, uncompensated immediate-family transactions, specified personal investments, and qualifying transactions involving a main home and up to two secondary homes. The notice also prescribes special treatment to the activity of portfolio managers, investment committee members, contractual arrangements, certain banking-related securities activities, and allocation agreements between firms. For more information, please review our prior alert linked above.