How effective and efficient are FINRA’s rules governing the outside business activities and private securities transactions of broker-dealer employees? As part of its FINRA360 initiative, the regulator is conducting a "Retrospective Rule Review" in which it seeks answers to the following questions:

• Have the rules effectively addressed the problem(s) they were intended to mitigate? To what extent have the original purposes of and need for the rules been affected by subsequent changes to the markets, the delivery of financial services, the applicable regulatory framework, or other considerations? Are there alternative ways to achieve the goals of the rules that should be considered?

• What have been experiences with implementation of the rule set, including any ambiguities in the rules or challenges to comply with them?

• What have been the economic impacts, including costs and benefits, arising from FINRA’s rules? Have the economic impacts been in line with expectations described in the rulemaking? To what extent would these economic impacts differ by business attributes, such as size of the firm or differences in business models?

• Can FINRA make the rules, interpretations or attendant administrative processes more efficient and effective?

Please submit your comments by 6/29/17.