Other Account-Activity Controls

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What this video covers

  • Why continuing commissions to terminated or retired representatives require a bona fide written contract entered into while the rep was still registered, and why any ongoing customer contact by the unregistered rep destroys the exception
  • The 3-month dividing line for mail holds, where convenience is acceptable up to 3 months but an acceptable reason (extended travel, medical relocation, military deployment) is required beyond that threshold
  • Why firms must verify customer address and contact information at reasonable intervals during any mail hold, and how failure to re-verify creates a standalone violation
  • The express written authorization requirement before initiating any debit from a customer's bank account via automated clearing house (ACH), check-writing privileges, or direct advisory-fee debits, and why verbal approval never satisfies the rule
  • The 3-year records-retention clock for negotiable instrument authorizations measured from the date the authorization expires, not from the date it was created
  • The issuer-level financial review and documented reasonable-basis requirement before any over-the-counter (OTC) equity recommendation, including the mandatory inquiry when an issuer is a delinquent Securities and Exchange Commission (SEC) filer
  • Why Direct Participation Program (DPP) suitability operates as a second layer on top of general suitability and Regulation Best Interest (Reg BI), requiring affirmative collection of participant-specific income, net worth, and tax status data

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