Confidentiality of Customer Information
Chapters in this video
- 0:00 What customer information is: confidential, not a free-for-all
- 1:05 Section 1, the fiduciary hats: paying agent, transfer agent, trustee
- 2:05 The transfer agent trap: data for the job, not for the pitch
- 4:27 Section 2, the issuer request exception: two boxes to check
- 5:55 The permitted-prohibited matrix for test day
- 6:23 Section 3, the five-step exam day checklist
- 8:01 Rapid-fire exam recap
What this video covers
- Why customer information is not a general firm resource, and how access controls apply both internally and externally
- The operational test: whether the recipient has a permitted purpose for every handoff of customer data
- The four fiduciary hats (paying agent, transfer agent, trustee, similar capacity) that trigger strict usage restrictions
- Why fiduciary ownership information cannot be used to solicit purchases, sales, or exchanges for the member's own benefit
- The critical distinction between performing the fiduciary function and pivoting to a sales pitch
- The two-part issuer request exception: issuer must explicitly request, and the member must act solely on the issuer's behalf
- Why the member cannot use the issuer exception as a disguise for its own solicitation
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 99 course also includes adaptive practice questions and spaced-repetition flashcards, free through the end of 2026.