FINRA Series 6 Investment Company and Variable Contracts Products Representative ExaminationProfessional Conduct and Ethical ConsiderationsMedium

A registered representative (RR) is informed by a client that they are considering naming their RR as the beneficiary of a significant portion of their individual retirement account (IRA). The client has no close family members and views the RR as a trusted friend and advisor. What is the most appropriate action for the RR to take regarding this request?

  1. AAccept the designation but immediately transfer the client to another RR to avoid conflict.
  2. BAccept the designation, as it reflects the client's wishes and trust.
  3. CDecline the designation and explain that firm and regulatory rules prohibit such arrangements.
  4. DAccept the designation only if the firm provides explicit written approval.
Show answer & explanation

Correct answer: C. Decline the designation and explain that firm and regulatory rules prohibit such arrangements.

FINRA Rule 3241 (Prohibition on Being Named a Customer's Beneficiary or Holding a Position of Trust) generally prohibits RRs from being named as a beneficiary to a customer's estate or holding a position of trust (like executor or trustee) unless specific conditions are met, such as the customer being a family member or the firm provides written approval under very limited circumstances. Given this is a non-family client, the RR should decline the request.

Why the other options are wrong

  • A. Transferring the client does not resolve the ethical and regulatory issue of the RR being named beneficiary.
  • B. Accepting would violate FINRA rules designed to prevent conflicts of interest and exploitation of clients.
  • D. While firm approval is required for any exceptions, it is highly unlikely to be granted for a non-family client, and the general rule is prohibition.

Beneficiary Designation Prohibition (Non-Family)

FINRA Rule 3241 generally prohibits registered representatives from being named as a beneficiary of a non-family customer's estate or account, or from holding a position of trust (e.g., executor, trustee) for such a customer, to prevent conflicts of interest and potential exploitation.

  • Protects vulnerable clients.
  • Prevents conflicts of interest.
  • Family member exception exists with firm approval.

Memory trick: Beneficiary? No, unless family, then firm says go.

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