Suitability's Three Obligations
Chapters in this video
- 0:00 The three flaming suitability hurdles
- 1:05 Reasonable-basis suitability: product understanding first
- 2:22 Investment profile vs. Know Your Customer essential facts
- 3:22 Quantitative suitability: pattern of activity not isolation
- 4:47 Quantitative suitability vs. churning: control and intent
- 5:29 The standalone financial ability prohibition
- 6:02 Rapid-fire exam recap
What this video covers
- Whether reasonable-basis suitability can fail before any customer is ever considered, and why product understanding through reasonable diligence comes first
- How the suitability rule's investment profile (age, tax status, financial situation, liquidity needs, risk tolerance, and more) differs completely from Know Your Customer's essential facts
- What customer-specific suitability requires: matching the product to this particular customer using the investment profile, not the essential facts list
- Why quantitative suitability looks at a series of recommendations together and requires the pattern be both excessive and unsuitable, not merely active
- How quantitative suitability differs from churning: no control or intent element is required for the former, but both control and intent to generate commissions are required for the latter
- The standalone prohibition on recommending a transaction, continuing purchase, or strategy unless the customer has the financial ability to meet that commitment
- Why financial ability to afford the purchase is not the same as holding power, which concerns withstanding volatility after ownership
Read the full lesson, free
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