Ann Began Furman

In March 2025, the Financial Industry Regulatory Authority (FINRA) published and requested comment on a proposed new “outside activities” Rule 3290 that would combine and replace Rules 3270 (outside business activities) and 3280 (private securities transactions) and focus only on “investment-related” outside activities of registered personnel. See “FINRA’s Symphonic Reimagining of Its OBA and PST Rules,” Expect Focus – Life, Annuity, and Retirement Solutions (August 2025).

Not content to “let it be,” the Financial Services Institute (FSI) sought and received, on November 17, 2025, a significant SEC staff no-action letter relating to the broker-dealer status of personal service entities (PSEs) owned by registered representatives.

In a section titled “Annuities Securities Products,” FINRA’s 2025 Annual Regulatory Oversight Report, issued on January 28, 2025, addresses regulatory obligations related to the sales of variable annuities (VAs) and registered index-linked annuities (RILAs). FINRA’s report includes RILAs as a topic for the first time, presumably due to the significant growth of the product in recent years. RILA sales in 2024 reached $65.2 billion, a 37% increase from 2023 sales of $47.4 billion.