Other Account-Activity Controls
Chapters in this video
- 0:00 The four edge-case rules outside standard suitability
- 1:18 Continuing commissions to unregistered persons
- 2:28 Mail holds and the 3-month convenience cutoff
- 4:13 Negotiable instruments: express written authorization
- 5:05 3-year retention from expiration, not creation
- 6:04 OTC equity recommendation review requirements
- 7:47 DPP suitability: issuer-level vs participant-level review
- 10:15 Rapid-fire exam recap
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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