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Compliance & Licensing

Important Reminder on Outside Business Activities (OBAs)

By December 17, 2025No Comments

All OBAs are required to be disclosed and approved before engaging in the activity. You must also notify your supervisor and ESI of changes to, or termination of, an existing OBA.

Failure to disclose activities and/or keep them current can result in disciplinary actions by FINRA, the state, or the b/d.

Examples of OBAs that must be disclosed include, but are not limited to:

  • Your activities as an insurance agent;
  • Practicing as a CPA, lawyer, or Enrolled Agent;
  • Your DBA or being a member, owner, or participant in a legal entity, such as an LLC;
  • Fees for referring business to someone else;
  • Any other home-based or small business enterprises;
  • Real estate activities, such as owning a rental property or leasing or renting land;
  • Any outside employment not related to securities;
  • Serving in a fiduciary capacity (e.g. trustee, power of attorney, attorney-in-fact, executor) for a family trust of an immediate family member;
  • Any activity where compensation is paid including part-time jobs; though compensation is not needed to classify an activity as an OBA;
  • Any volunteer or unpaid position where you are in a leadership position or if you handle/have access to funds, vote on disbursement of funds, or collect money/fundraise.

OBAs must be disclosed and approved prior to engaging in the activity. To do so, rep’s must complete an OBA Disclosure form (available on the NL Portal in ‘Forms & Materials’), send to the field Supervisor for review/sign off, and then submit to ESI Licensing for review and processing.

If the Firm has no objection, you’ll receive an email confirmation that your OBA has been approved. Take note of any restrictions listed for you to be compliant while engaging in the activity. Remember – you may not engage in the proposed activity until you’ve received the Firm’s approval.

Failure to report a new OBA, changes to an existing one, or terminate a ceased activity may result in disciplinary action.

If you are unsure if an activity should be disclosed, please ask ESI!

Please review, while logged into the Agent Portal, the Firm’s Written Supervisory Procedures section 2.3 and Field Notice 2022-20 for more information.