NASAA Series 63Communication with Customers and ProspectsHard

A registered agent is preparing a sales presentation for a seminar aimed at prospective clients. Which of the following disclosures is LEAST likely to be required in such a presentation under the Uniform Securities Act?

  1. AThat the securities are registered with the state Administrator.
  2. BThat the agent or the firm may have a conflict of interest in recommending certain products.
  3. CThe fees and commissions associated with the services or products being discussed.
  4. DThe investment objectives and risks associated with any recommended strategies.
Show answer & explanation

Correct answer: A. That the securities are registered with the state Administrator.

While securities must be registered (or exempt from registration), it is generally prohibited to state or imply that the registration of a security or an investment adviser with the Administrator constitutes an endorsement or approval by the state. Therefore, explicitly stating that securities are 'registered with the state Administrator' in a way that implies approval is misleading and not a required disclosure in a sales presentation.

Why the other options are wrong

  • B. Disclosure of conflicts of interest is a critical requirement.
  • C. Clear disclosure of fees and commissions is a standard requirement.
  • D. Disclosure of investment objectives and risks is fundamental to investor protection.

Prohibited Regulator Approval Claims

Under the Uniform Securities Act, it is unlawful to state or imply that registration of a security or a person (e.g., agent, IA) with a regulatory authority constitutes an endorsement or approval by that authority.

  • Registration is not approval.
  • Cannot imply state endorsement.
  • Misleading to suggest regulatory approval.
  • This is a prohibited representation, not a required disclosure.

Memory trick: Required disclosures are the 'yes' list, prohibited are the 'no' list, like traffic signs.

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