Associated Persons and the Registration Framework

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What this video covers

  • The exact scope of FINRA By-Laws Article I(rr): who is an associated person (AP) including policy-makers, part-timers, and common-control affiliate staff
  • Why a chief financial officer (CFO) with zero customer contact is still an associated person subject to fingerprinting and statutory disqualification screening
  • The two-step registration test: associated person status first, then engagement in the investment banking or securities business second
  • Why failing either step of the two-tier test means no registration is required, and the difference between associated status and registered status
  • The two-principal minimum for member firms and the product-specific exceptions for mutual funds, variable products, and options
  • What permissive registration is, why it is not a lighter form of registration, and why permissively registered persons must complete the regulatory element of continuing education by December 31st each year
  • How active registration and permissive registration create identical FINRA rule obligations for continuing education and compliance

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