NASAA Dishonest Practices: Compensation Provisions
Chapters in this video
- 0:00 How federal and state fair-pricing rules mirror each other
- 1:07 The price gouge: unfair pricing and double jeopardy
- 2:37 The golden paperweight: unreasonable non-transaction service fees
- 4:16 The treadmill: induced excessive trading and the two-part NASAA test
- 6:22 The buddy system: unregistered commission splitting
- 7:14 Rapid-fire exam recap
What this video covers
- Why unfair pricing at the state level mirrors federal fair-pricing rules, creating dual enforcement exposure for a single violation
- The specific NASAA prohibition on transactions at prices not reasonably related to current market price, and on unreasonable commissions or profits
- How unreasonable and inequitable fees for non-transaction services (safekeeping, custody, appraisals, transfers, collection of principal or dividends) are independently violative under NASAA's dishonest practices policy
- The exact two-part test NASAA states for excessive trading: firm-induced trading that is excessive in size or frequency relative to the customer's financial resources and account character
- Why turnover ratios, control of the account, and commission-seeking intent are evidentiary indicators in broader churning analysis but are NOT required elements under NASAA's written provision
- The critical distinction between customer-directed frequent trading and firm-induced excessive trading when evaluating churning violations
- The narrow permitted scope of commission splitting: only with another registered agent at the same broker-dealer or an affiliated broker-dealer under direct or indirect common control
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