Reasonable and Non-Discriminatory Service Charges
Chapters in this video
- 0:00 What ancillary service charges actually are
- 0:40 Covered services and the open-list trap
- 1:35 Bucket sorting: trade pricing vs. ancillary fees
- 2:23 The non-discrimination rule among similarly situated customers
- 2:52 The reasonableness test and the fixed-dollar-cap trap
- 3:25 Why ancillary fees matter for portfolio risk
- 3:52 Rapid-fire exam recap
What this video covers
- How to sort a fee into the correct regulatory bucket: the fair-pricing and commission rule for the trade itself, or the reasonableness standard for everything else
- The specific services covered by the ancillary charge standard, including collection of monies, exchange or transfer of securities, safekeeping, custody, and the open-list trap of "including, but not limited to"
- Why the standard applies to any miscellaneous service charge of the same kind, not only the enumerated examples
- The two-part test that every ancillary charge must pass: reasonable in amount and not unfairly discriminatory among similarly situated customers
- The biggest exam trap for this topic: searching for a fixed dollar cap when the rule contains none, only a fact-based reasonableness evaluation
- Why this standard lives inside portfolio risk disclosures, since ancillary fees are a real cost drag on a customer's bottom line beyond commissions and mark-ups
Read the full lesson, free
This video's complete written lesson is free to read in the CertFuel app, no signup wall. The complete Series 82 course also includes adaptive practice questions and spaced-repetition flashcards, available in Free Beta.