On January 22, 2026, FINRA filed a proposed rule (January 2026 Proposal) with the SEC that would create new FINRA Rule 3290 on outside business activities (OBAs) to replace Rules 3270 and 3280, which set OBA and private securities transactions (PSTs) reporting requirements for FINRA members. FINRA argued that Rule 3290 will streamline the reporting of OBAs and PSTs that persons must make to member firms to obtain approval and avoid conflicts of interest. In FINRA’s view, the two existing rules are misaligned with a market in which hundreds of  and thousands of individuals engage in low-level OBAs, such as tending bar, which are functionally irrelevant to the investment-related activities they may perform on behalf of members. Hence, adopting more focused requirements will exclude such “white noise” from reporting channels and lessen recordkeeping and compliance burdens. But some question the potential effectiveness of Rule 3290 while Form U4 – which is used to report, among other things, OBAs – is still in effect. This article charts the evolution of the January 2026 Proposal from the original proposal made on March 14, 2025, when FINRA issued Regulatory Notice 25-05 (March 2025 Proposal); breaks down what it retains from current rules and how it departs from them; compares it to Form U4; and weighs the likelihood and timeline of potential approval by the SEC and adoption in its current form, with commentary from legal experts. For a look at the March 2025 Proposal, see “FINRA Requests Comment on Revised Rules for Outside Business Activities and Securities Transactions” (Jun. 5, 2025).