Customer Privacy: Rapid Fire
Chapters in this video
- 0:00 Fiduciary information and the solicitation ban
- 1:14 Regulation S-P versus Regulation S-ID red flags
- 2:36 Opt-out default and hidden nonpublic personal information
- 4:40 OBO objects, NOBO does not: beneficial owner disclosure
- 6:08 OBO and NOBO do not change ownership status
- 6:53 Rapid-fire exam recap
What this video covers
- Why fiduciary ownership information from a paying agent, transfer agent, or trustee cannot be used for solicitation unless the issuer requests it and the member acts solely on the issuer's behalf
- How Regulation S-P protects customer information through privacy notices, opt-out rights, safeguards, and secure disposal procedures
- Why a privacy notice alone is insufficient and the full internal control package is mandatory
- When nonpublic personal information (NPI) stays protected even after being mixed into a larger data set containing public information
- Why opt-out is the default for most nonaffiliated-third-party disclosures, not opt-in
- What objecting beneficial owner (OBO) and non-objecting beneficial owner (NOBO) elections mean for identity disclosure to issuers of nominee-held securities
- Why Regulation S-ID requires a written program to detect, prevent, and mitigate identity theft red flags in covered accounts, separate from Regulation S-P privacy protections
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