Registration and Post-Registration Requirements: Rapid Fire

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What this video covers

  • Why federal registration with the Securities and Exchange Commission (SEC) and Financial Industry Regulatory Authority (FINRA) does not satisfy any state requirement, and why registration is strictly per state
  • What Form BD is, what accompanies it, and why the irrevocable consent to service of process is one-time, non-renewing, and survives termination
  • The exact books and records retention periods: 3 years for correspondence, advertising, and written supervisory procedures (WSPs); 4 years for customer complaints; 6 years for blotters, ledgers, and customer account records; and the 2-year easily accessible rule
  • Why a state Administrator can examine records at any time, inside or outside the state, without a subpoena, but cannot impose requirements that conflict with or exceed federal standards on capital, custody, margin, records, bonding, or reporting
  • The six punitive actions that each require both a public interest finding and a statutory ground: denial, suspension, revocation, bar, censure, or restriction
  • Why cancellation is non-punitive housekeeping with none of those requirements, limited to its own four specific findings
  • The 30-day effective rule for both registration and withdrawal, the December 31 annual expiration, the 10-year lookback for felonies and securities-related misdemeanors, and the 90-day window to act on disclosed prior orders

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