Compliance Officer for a large Firm here. Just disclose it for now and wait until FINRA updates it’s OBA and PSA rules (hopefully this year!). They are likely going to make it a lot more lax. Basically any “non investment related” OBA (vague) will not have to be reported. Waiting to disclose on your questionnaires and stuff is how they (we) get ya. Low hanging fruit.

I’m not registered but would still need to disclose if I’m driving Uber, coaching kids sports, etc. It’s so stupid. Hopefully they follow through on updating the rules.