FINRA Series 6 Investment Company and Variable Contracts Products Representative ExaminationOpening and Maintaining Customer Accounts and Investment RecommendationsMedium
A new client opens an account and provides their Social Security Number, but declines to provide their date of birth. Under FINRA rules, can the registered representative open the account?
- ANo, a date of birth is considered essential information for customer identification and suitability.
- BYes, as long as the client provides a valid government-issued ID.
- CYes, if the client signs a waiver stating they refuse to provide their date of birth.
- DNo, unless the firm has an exception policy for this type of situation.
Show answer & explanationAnswer & explanation
Correct answer: A. No, a date of birth is considered essential information for customer identification and suitability.
FINRA Rule 2090 (Know Your Customer) and AML regulations require firms to obtain essential information to verify identity and assess suitability, which includes date of birth. Without it, the account cannot be opened.
Why the other options are wrong
- B. While a government ID helps verify identity, the date of birth is still a required piece of information for the New Account Form.
- C. A waiver does not exempt the firm or representative from regulatory requirements to collect essential customer information.
- D. There are no general exception policies that bypass the requirement to collect a customer's date of birth for account opening.
Essential Customer Information
Information mandated by FINRA rules (e.g., Rule 2090) to be collected from customers to verify identity, assess suitability, and comply with AML regulations.
- Includes name, address, SSN/TIN, date of birth.
- Required for all new accounts.
- Crucial for suitability and anti-money laundering (AML) compliance.
Memory trick: To know your customer, you need their birth-date, not just their ID.