Opening accounts accounts for nine of the 50 scored Series 82 questions. The core task is keeping different checks separate: who the customer is, who can act, whether the investor qualifies, and what the customer needs from the investment. One completed document rarely answers all four.
Is identity verification the same as knowing your customer?
No. Confirming identity is one task; understanding the essential facts about the relationship is broader. FINRA Rule 2090 addresses the essential facts concerning the customer and the authority of people acting on the customer’s behalf.
For example, confirming the identity of someone signing for a trust does not establish that the trust permits the proposed investment or that the signer has the necessary authority. The relevant trust documents and account procedures still matter. A personal signature is evidence of a person’s action, not automatic proof of their power to bind an entity.
What belongs in the customer profile?
A useful profile covers the customer’s financial situation, objectives, experience, time horizon, and liquidity needs, as applicable. FINRA Rule 4512 specifies customer-account information, while the exam outline connects the profile to the investment decision.
Suppose an investor reports substantial assets but needs a large cash payment in six months. A long-term illiquid investment creates a question that net worth alone cannot answer. Record the need, assess its implications, and do not replace the customer’s actual circumstances with “high-net-worth client.”
If the facts change after the account opens, the firm’s review should use current information. Opening a file once does not mean its contents remain accurate forever.
Does accredited-investor status settle the recommendation question?
No. Qualification to participate in an offering is separate from whether a recommendation meets the applicable conduct standard. A wealthy investor can have a short time horizon, concentrated exposure, or insufficient liquid assets for upcoming obligations.
For a Rule 506(c) offering, the issuer must also take reasonable verification steps. The SEC’s Rule 506(c) guidance explains that accredited status and verification are requirements even though broad solicitation is allowed. A questionnaire should not be treated as a universal substitute for the required analysis.
Compare this with the private-offerings guide, where the first question is which exemption applies. Identifying the exemption tells you which participation and communication requirements to evaluate.
What should happen when documents conflict?
Resolve the discrepancy before proceeding through a step that depends on the disputed information. If an account application lists one authorized signer and an entity resolution lists another, the representative should obtain clarification through the firm’s procedures rather than choose the easier document.
The same reasoning applies to inconsistent financial information. A subscription request does not eliminate the need to understand a conflicting investor profile. Escalating an unresolved issue is different from accusing the customer of wrongdoing; it is the process for getting an adequate basis to act.
What is a useful account-opening practice exercise?
Take a scenario and label each fact as identity, authority, investor qualification, or customer objectives. Then identify what remains unknown. This forces you to see why a complete identity check may coexist with an incomplete account decision.
Continue with the recommendations guide and try the accounts questions in the practice test. The Series 82 topic directory connects all four functions to the same customer relationship.
For focused practice, try investor-qualification questions.