Customer Investment Profiles and Suitability: Rapid Fire
Chapters in this video
- 0:00 KYC always on, even when a customer refuses to share data
- 1:58 Retail Reg BI versus institutional FINRA suitability: the two paths
- 2:32 What counts as a recommendation: hold, strategy, and the current-profile trap
- 3:23 Three cumulative suitability layers and the 2020 control removal
- 5:03 Four Reg BI obligations and the sales-contest elimination rule
- 6:31 Institutional exemption at $50 million and affirmative indication
- 6:59 Form CRS page limits, retail investor scope, and 30- versus 60-day deadlines
- 7:43 MSRB municipal overlay: when Reg BI preempts and when tools stack
- 9:03 Rapid-fire exam recap
What this video covers
- Why KYC is always active in every account, and what happens when a customer refuses to provide profile information
- The exact definition of a recommendation, including why "hold" advice and strategy suggestions trigger suitability even without naming a security
- The three cumulative suitability obligations (reasonable-basis, customer-specific, quantitative) and why control is no longer required for quantitative violations
- The four Reg BI obligations (disclosure, care, conflict of interest, compliance) and why partial compliance creates no safe harbor
- When the $50 million institutional-customer exemption applies, which layer it waives, and why affirmative indication of independent judgment is required
- Form CRS delivery rules, page limits, and the critical 30-day versus 60-day deadlines
- Why Reg BI preempts the Municipal Securities Rulemaking Board (MSRB) suitability rule for retail customers, and when the investment-analysis-tool rule stacks on top instead
Read the full lesson, free
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