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What is Know Your Customer (KYC)?

The FINRA Rule 2090 duty of a broker-dealer to use reasonable diligence to know and retain the essential facts about every customer and about the authority of each person acting for that customer.

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Definition

Know Your Customer (KYC)

Laws & Regulations High Relevance

The FINRA Rule 2090 duty of a broker-dealer to use reasonable diligence to know and retain the essential facts about every customer and about the authority of each person acting for that customer. The duty applies when opening and maintaining every account and covers the facts needed to service the account, follow any special handling instructions, understand who may act on it, and comply with applicable laws and rules, including Anti-Money Laundering (AML) requirements. In common usage, KYC also covers the investment profile (age, other investments, financial situation and needs, tax status, investment objectives, investment experience, time horizon, liquidity needs, and risk tolerance), which a broker-dealer must ascertain under the separate suitability obligations: FINRA Rule 2111 or, for a recommendation to a retail customer, Regulation Best Interest. An investment adviser makes a reasonable inquiry into a client's investment objectives, financial situation and needs; the Financial Crimes Enforcement Network rule extending AML programs to most SEC-registered investment advisers and to exempt reporting advisers is scheduled to take effect January 1, 2028. KYC is an ongoing obligation that begins at account opening and requires updates when client circumstances materially change.

// EXAMPLE

During account opening, an investment adviser gathers information showing a client is 45 years old, earns $150,000 annually, has $500,000 in savings, seeks growth with moderate risk, has a 15-year time horizon for retirement, needs $50,000 emergency fund liquidity, has 10 years investment experience, and is in the 32% tax bracket. This complete KYC profile enables suitable investment recommendations.

// COMMON_CONFUSION

Students often think KYC is a one-time requirement completed only at account opening, when it is actually an ongoing obligation requiring updates when circumstances change. Others confuse KYC (gathering client information) with suitability (using that information to make appropriate recommendations) or AML (using KYC data to detect suspicious activity). KYC is the foundation that enables both suitability analysis and AML compliance.

How is Know Your Customer (KYC) tested on the exam?

  • Identifying the investment profile factors (age, other investments, financial situation and needs, tax status, investment objectives, experience, time horizon, liquidity needs, risk tolerance)
  • Understanding when KYC information must be gathered (account opening) and updated (material changes in circumstances)
  • Recognizing that inadequate KYC information prevents meeting customer-specific suitability obligations
  • Distinguishing between KYC requirements for suitability (investment profile) versus AML requirements (identity verification)
  • Understanding that recommendations made without adequate KYC violate both suitability obligations and fiduciary duty

Regulatory limits

Regulatory Limits

Description Limit Notes
Investment profile factors for suitability (FINRA Rule 2111; the same factors under Regulation Best Interest) Age, Other investments, Financial situation and needs, Tax status, Investment objectives, Experience, Time horizon, Liquidity needs, Risk tolerance The profile includes, but is not limited to, these factors and any other information the customer discloses; under Rule 2111 a firm may treat a factor as not relevant only with a reasonable basis documented with specificity
KYC verification timing At account opening and when circumstances materially change Ongoing obligation, not one-time requirement
KYC for AML (Customer Identification Program) Name, date of birth, residential or business street address, identification number (TIN for a U.S. person) Verified by documents (such as a government-issued photo ID), non-documentary methods, or both (31 CFR 1023.220)

Think of KYC like a doctor taking medical history before treatment: You cannot prescribe medication without knowing the patient's conditions, allergies, and health goals. Similarly, you cannot recommend investments without complete client information. Remember "FIT-TLER" for 7 of the profile factors (the suitability rule also lists age and other investments): Financial situation, Investment objectives, Tax status, Time horizon, Liquidity needs, Experience, Risk tolerance. KYC is the foundation that enables suitable recommendations.

Practice questions

Test your understanding with the questions below. Pick an answer to reveal the explanation.

Question 1

Thomas, a new investment adviser representative, meets with Lisa, a prospective client. During their 15-minute phone call, Lisa mentions she wants "to make money" and has $100,000 to invest. Thomas recommends a portfolio of small-cap growth stocks and emerging market funds without asking about her age, time horizon, risk tolerance, liquidity needs, or financial situation. Two months later, Lisa complains that the portfolio has lost 18% and she needed the money for a home down payment in 6 months. What is Thomas's primary violation?

Question 2

What is the primary purpose of the Know Your Customer (KYC) requirement for investment advisers and broker-dealers?

Question 3

An investment adviser representative gathers the following information from a new client: age 55, married, household income $180,000, current savings $400,000, wants "steady income with some growth," describes himself as "moderately risk-averse," and has 15 years until planned retirement. Which additional KYC information is needed to meet suitability obligations?

Question 4

All of the following are required elements of Know Your Customer information for meeting suitability obligations except

Question 5

A registered investment adviser has gathered complete Know Your Customer information from four clients. Which of the following scenarios indicate that KYC information should be updated?

1. A client turns 59ยฝ years old and can now access IRA funds without penalty
2. A client receives a $2 million inheritance from a deceased parent
3. A client's risk tolerance changes from aggressive to risk-averse after experiencing a 30% portfolio decline
4. A client's account value rises 2% over a quarter with no change in income, objectives, or plans

What concepts relate to Know Your Customer (KYC)?

This term is part of these clusters :

Where does Know Your Customer (KYC) appear on the Series 65 exam?

This term is tested in the following Series 65 exam topics:

Where does Know Your Customer (KYC) appear on the Series 6 exam?

This term is tested in the following FINRA Series 6 topic areas:

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