In January 2021, a registered representative associated with IRC disclosed to IRC in writing that he had begun issuing promissory notes on behalf of a disclosed outside business activity (OBA). IRC failed to evaluate whether this activity was properly characterized as an OBA or whether it should instead be treated as an outside securities activity subject to the requirements of FINRA Rule 3280. As a result, IRC violated FINRA Rules 3270.01 and 2010.