Account Registration Changes and Internal Transfers

What this video covers

• Whether a change is customer-driven or firm-driven, and why both trigger the exact same duty to update the account record
• The sleeping bear rule for legacy accounts: why older accounts are not automatically deficient and when full compliance suddenly attaches
• When the trusted contact person disclosure must be delivered, and why it is tied to the first update of a legacy account
• Why the six-year retention clock resets from the date of each update, not from the original account opening date
• Whether reassigning an account to a different associated person internally counts as a recordkeeping event (it does)
• How shared responsibility among multiple associated persons must be documented, including the precise scope split and keeping it current as duties shift
• How exam fact patterns blend these triggers together to hide which event started the compliance chain