Regulations·Customer Accounts

Customer Accounts

Account Ownership Types

Understanding how accounts are titled determines what happens to the assets on death and who has authority to make decisions. This is heavily tested on the Series 7.

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Joint Tenancy with Right of Survivorship (JTWROS)

In a JTWROS account, two or more individuals share ownership equally. The critical feature: right of survivorship. When one co-owner dies, their interest automatically passes to the surviving co-owner(s) -- it does NOT go through the deceased's estate or will.

Real-world example: A husband and wife hold a brokerage account as JTWROS. The husband dies. The entire account immediately belongs to the wife, regardless of what the husband's will says. The account bypasses probate entirely.

Key features:

  • All tenants have equal rights to the account
  • Ownership must be equal (cannot hold 70/30 in JTWROS)
  • Survivorship overrides the will
  • Most common for married couples
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    Tenants in Common (TIC)

    In a TIC account, two or more individuals share ownership, but each owns a specified percentage interest that can be unequal. When one co-owner dies, their interest passes to their estate (governed by their will or state intestacy laws) -- NOT to the surviving co-owners.

    Real-world example: Two business partners hold real estate as TIC, with one owning 60% and one owning 40%. When the 60% partner dies, her 60% interest goes to her heirs, not to the surviving partner.

    Key exam distinction: JTWROS = survivorship (bypasses estate); TIC = goes through estate.

    All co-owners must authorize transactions in a TIC account unless one has been granted trading authority.

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    Custodial Accounts: UGMA and UTMA

    When adults want to gift assets to minor children, they use custodial accounts:

    UGMA (Uniform Gifts to Minors Act): Allows cash and securities as gifts. The minor is the beneficial owner; the custodian manages the account until the minor reaches the age of majority (18 in most states).

    UTMA (Uniform Transfers to Minors Act): Broader than UGMA -- allows any type of asset (real estate, patents, art, securities). Age of majority can be extended to 21 or even 25 in some states (state-specific).

    Key rules for both:

  • One custodian, one minor per account -- a single custodian manages assets for one minor child
  • Gifts are irrevocable -- once given, the custodian cannot take assets back
  • The custodian must manage assets prudently in the minor's best interest
  • When the minor reaches the age of majority, they receive full control unconditionally
  • Transfers count toward the annual gift tax exclusion ($18,000 per person in 2024)
  • Kiddie tax: Investment income over a threshold (~$2,500 in 2024) in a child's custodial account is taxed at the parent's marginal rate until the child reaches age 19 (or 24 if a full-time student).

    UGMA vs. UTMA distinction: UTMA is broader (more asset types) and may delay transfer to an older age.

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    Corporate Accounts

    When a corporation opens a brokerage account, specific documentation is required:

  • Corporate resolution: A formal document signed by the board of directors authorizing the account and specifying which officers are authorized to transact
  • Articles of incorporation
  • Corporate charter
  • The corporation -- not any individual officer or employee -- is the account owner. Only individuals named in the corporate resolution may transact in the account.

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    Trust Accounts

    Trusts are legal entities that hold assets for the benefit of beneficiaries. When a trust opens a brokerage account:

  • The trust document must be provided
  • The trustee (who manages the trust) is identified
  • The trustee has a fiduciary duty to act in the beneficiaries' interest
  • The trustee's authority is limited by the terms of the trust document
  • The brokerage account is held in the name of the trust, not the individual trustee.

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    Discretionary Accounts

    A discretionary account gives the registered representative the authority to make investment decisions (choose security, quantity, buy/sell) without obtaining the customer's prior approval for each trade.

    Requirements:

  • Written discretionary authority must be obtained from the customer before any discretionary trades are placed (a verbal agreement is insufficient)
  • The authority must be filed with the broker-dealer
  • Discretionary accounts require heightened supervision by the principal
  • All discretionary trades must be marked "discretionary" on the order ticket
  • The principal (branch manager) must review discretionary accounts frequently
  • Limits on discretion: Even with discretionary authority, a rep cannot:

  • Withdraw cash from the account
  • Change the account beneficiary
  • Make excessive trades (churning)
  • Time and price discretion: If a customer says "buy 100 shares of AAPL today" but leaves the exact timing and price to the rep, this is NOT discretionary trading (the security and quantity were specified). Only when the rep chooses the security itself or the quantity is it considered discretionary.

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    Numbered Accounts

    Accounts may be numbered (rather than in the customer's name) for privacy. The broker-dealer must have documentation on file confirming the customer's identity and their association with the numbered account. A registered representative cannot open a numbered account without this verification.

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    New Account Form Requirements (FINRA Rule 4512)

    FINRA Rule 4512 requires broker-dealers to obtain and maintain specific customer information:

    Required at account opening:

  • Customer's name and address
  • Date of birth
  • Social Security Number or Tax ID
  • Occupation and employer name/address
  • Whether the customer is a FINRA member or employed by one
  • Whether the customer is a senior officer or 10%+ shareholder of a public company
  • Not required but recommended for suitability purposes:

  • Investment objectives
  • Risk tolerance
  • Financial situation (income, net worth)
  • Updating customer information: Customer information must be reviewed and updated at least every 36 months (3 years). If a customer provides material updates (job change, change in financial situation, change in objectives), the account information should be updated immediately.

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    Key Terms

  • JTWROS: Joint account with right of survivorship; assets pass to surviving owners, bypassing the estate
  • TIC (Tenants in Common): Joint account where each owner's interest passes through their estate, not to co-owners
  • UGMA: Custodial account for minors; allows cash and securities; irrevocable gift
  • UTMA: Broader custodial account; allows any asset type; state-specific age of majority
  • Corporate resolution: Board authorization required to open and operate a corporate brokerage account
  • Discretionary account: Rep makes buy/sell decisions without prior customer approval; requires written authorization
  • FINRA Rule 4512: Requires collection and maintenance of specific customer information at account opening
  • 36-month update requirement: Customer information must be reviewed every 3 years at minimum
  • Time and price discretion: Specifying only timing/price (not security/quantity) -- NOT discretionary
  • Irrevocable gift: Custodial account contributions cannot be taken back by the donor/custodian

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Quiz Questions:

Q1. Husband and wife hold a joint brokerage account. The husband dies, leaving a will that bequeaths all of his assets to his adult children from a previous marriage. The account is titled as JTWROS. What happens to the account?

A) The account is split equally between the wife and the children per the husband's will B) The entire account passes to the wife by right of survivorship, regardless of the will C) The account is frozen until probate determines the proper distribution D) The children receive the husband's 50% interest per intestate succession rules

Answer: B -- Right of survivorship is the defining feature of JTWROS. When one co-owner dies, the survivor automatically inherits the entire account -- the deceased's will cannot override survivorship rights. The account bypasses the estate and probate entirely. The children receive nothing from this account (though they may have claims against other estate assets).

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Q2. A registered representative opens a custodial account for a customer's 8-year-old daughter under UTMA, with the customer designated as custodian. The customer later wants to reclaim $5,000 he deposited into the account to pay personal expenses. What is the MOST appropriate response?

A) The representative may return the funds because the account owner requested it B) The representative should process the withdrawal as the customer is the custodian C) The representative should refuse because UTMA gifts are irrevocable -- the funds belong to the minor D) The representative may return the funds if the customer signs a written request

Answer: C -- Gifts to custodial accounts (both UGMA and UTMA) are irrevocable. Once deposited, the funds legally belong to the minor. The custodian manages them in the minor's best interest but cannot withdraw funds for personal use -- doing so would be a breach of fiduciary duty and potentially misappropriation of the minor's assets. The broker-dealer should refuse and flag this request.

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Q3. A registered representative wants to begin making trading decisions in a customer's account without contacting the customer before each trade. What is required before the first discretionary trade is placed?

A) Verbal authorization from the customer during a recorded phone call B) Written discretionary authorization from the customer, filed with the broker-dealer C) Approval from the branch manager only D) No authorization is needed if the customer has previously expressed confidence in the rep

Answer: B -- Discretionary trading requires written authorization from the customer, obtained BEFORE the first discretionary trade. The written authorization must be filed with the broker-dealer. Verbal agreements (A) are insufficient. Manager approval alone (C) is not enough -- customer authorization is required. Prior verbal confidence (D) has no legal standing.

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Q4. Under FINRA Rule 4512, how often must a broker-dealer update customer account information at minimum?

A) Every 12 months (annually) B) Every 24 months C) Every 36 months D) Only when the customer requests an update

Answer: C -- FINRA Rule 4512 requires broker-dealers to update customer account information at least every 36 months (3 years). In addition, if a customer provides material new information at any time (change in employment, change in financial situation, change in objectives), it should be updated immediately. Annual updates (A) would also satisfy the rule but are not required.

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Q5. Two friends open a joint brokerage account as Tenants in Common, with Friend A owning a 70% interest and Friend B owning a 30% interest. Friend A dies. What happens to Friend A's 70% interest?

A) Friend B automatically inherits Friend A's 70% interest B) Friend A's 70% interest passes to Friend A's estate and is distributed according to Friend A's will C) The account is liquidated and proceeds split 70/30 with the 70% held in escrow D) Friend A's interest reverts to the broker-dealer until probate is completed

Answer: B -- In a Tenancy in Common account, there is no right of survivorship. Each owner's interest passes through their estate upon death. Friend A's 70% goes to Friend A's heirs per the will (or state intestacy laws if no will), NOT to Friend B. Friend B retains only his 30% interest. This is the fundamental contrast with JTWROS.