Required Disclosures on Specific Transactions
Chapters in this video
- 0:00 What Rita must disclose to Cora at recommendation
- 1:13 The six material aspects: objective through liquidity
- 2:16 Prospectus pushed vs. SAI pulled
- 3:35 What lives inside the SAI and the three-day rule
- 4:35 Summary prospectus and incorporation by reference
- 5:35 Ongoing events: stickers, votes, and notices
- 6:17 Control relationship with proprietary funds
- 7:09 The exact timing and dual violation risks
- 7:49 Rapid-fire exam recap
What this video covers
- What material information means in practice, and why disclosure is a continuous conversation rather than a one-time document dump
- The six material aspects a representative must cover at recommendation: objective, risks, costs, tax treatment, surrender terms, and liquidity restrictions
- Why the statutory prospectus is "pushed" (default delivery at or before confirmation) while the Statement of Additional Information (SAI) is "pulled" (on request only, free of charge, within three business days)
- How a summary prospectus satisfies the delivery requirement by incorporating the statutory prospectus by reference
- Which material events trigger prospectus supplements (stickers), which require shareholder votes, and which use source-of-distribution notices
- What constitutes a control relationship, including proprietary funds where the broker-dealer (BD) or affiliate is underwriter, sponsor, or investment adviser
- Why suitability never excuses a control relationship disclosure failure, and the exact timing (at or before completion of the transaction) that Reg BI and FINRA fair-dealing rules require
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