| name | finra-4512-customer-account |
| description | Drafts FINRA Rule 4512-compliant customer account records for broker-dealers. Use when onboarding customers, updating account information, or preparing for regulatory examinations. Triggers on requests involving customer account documentation, CIP/AML obligations, trusted contact designations, suitability profiling, or SEC Rule 17a-3 recordkeeping in broker-dealer contexts. |
| tags | ["checklist","drafting","regulatory"] |
FINRA Rule 4512 — Customer Account Information
Produces an examination-ready account record satisfying Rule 4512 mandatory/recommended data elements, suitability profiling, and supervisory sign-off.
Prerequisites
- Government-issued photo ID (license, passport, state ID)
- Tax ID — SSN (individual), EIN (entity), or TIN (trust/estate)
- Account type determined (individual, joint, custodial, corporate, trust)
- Intended trading authorizations (cash, margin, options level)
- Supervisory principal available for sign-off
Workflow
1. Customer Identification (Mandatory)
| Field | Notes |
|---|
| Full legal name | As on government ID; include suffix (Jr., Sr., II) |
| Physical residential address | No P.O. boxes (CIP requirement) |
| Date of birth | Age of majority varies by state (18/19/21); custodial if minor |
| Tax ID | SSN/EIN/TIN; obtain within 30 days if unavailable at opening |
| Phone, mobile, email | Note preferred contact; e-delivery consent date if applicable |
Custodial (UGMA/UTMA): Document minor's info AND custodian's identity, relationship, and authority basis.
2. Trusted Contact Person (Rule 4512(a)(1)(E))
Must be offered; strongly recommended for customers age 65+.
If designated — collect: full legal name, relationship, mailing address, phone (primary + mobile), email, designation date.
Scope: Trusted contact has NO account authority. Firm may contact only to: confirm contact info, confirm identity of guardian/trustee/POA holder, or address financial exploitation/diminished capacity concerns.
If declined: Document declination and date; note ability to add later.
3. Employment & Affiliation Disclosures
| Situation | Action |
|---|
| Securities industry employee (BD, RIA, exchange) | Document employer, position, licenses; arrange duplicate confirms/statements |
| Director/officer/≥10% shareholder of public company | Document company, ticker, position; monitor Section 16/blackout compliance |
| Customer or household member affiliated with FINRA member | Obtain prior written employer consent (Rule 3210); send duplicate confirms |
| Self-employed | Document business nature and entity structure |
"Immediate household" = spouse, domestic partner, financially dependent co-residents.
4. Investment Profile & Suitability (Rule 2111)
Objectives (prioritize and document rationale): capital preservation, current income, growth, speculation, balanced.
Risk tolerance: Document narrative response to scenarios (e.g., 20% decline over 6 months), not just checkbox. Flag inconsistencies with stated objectives.
Time horizon: Short-term 1–3 yr | Intermediate 3–10 yr | Long-term 10+ yr
Financial information (ranges acceptable):
| Field | Buckets |
|---|
| Annual income | <$50K / $50–100K / $100–250K / $250–500K / $500K+ |
| Liquid net worth | Same scale |
| Total net worth (excl. primary residence) | Same scale |
Experience by asset class (none / limited / moderate / extensive + duration): equities, fixed income, mutual funds/ETFs, options, futures/commodities, alternatives.
Special considerations: ESG preferences, sector exclusions, tax-advantaged strategies, anticipated liquidity events.
5. Account Features & Elections
| Feature | Required Documentation |
|---|
| Margin | Margin agreement executed; risk disclosure delivered; forced liquidation acknowledged |
| Options | Approval level assigned (L1–L4+); OCC disclosure delivered; receipt dated |
| E-delivery | E-SIGN consent; email confirmed |
| Dividend reinvestment | Election and effective date |
| Cash sweep | Elected sweep vehicle |
| Securities lending | Consent obtained; disclosure delivered |
Options levels: L1 covered calls → L2 + cash-secured puts → L3 spreads → L4+ uncovered/complex.
6. Certification & Supervisory Sign-Off
Both blocks require: printed name, CRD#, date, signature.
- Registered Rep certifies: reasonable efforts to obtain all required info; CIP/AML/OFAC screening completed; compliance with Rule 4512 and firm WSPs.
- Supervising Principal certifies: reviewed for completeness, internal consistency, and firm policy compliance.
7. Recordkeeping & Periodic Review
At each 36-month review: document date, reviewing rep, updated fields, and profile-current affirmation.
Pitfalls
- Declined info: Record "Customer declined — [date]" for any non-mandatory element refused
- P.O. box only: Insufficient for CIP; escalate if no physical address available
- Insider/affiliated accounts: Do not open until Rule 3210 consent obtained; trigger compliance review first
- Suitability conflicts: Resolve any mismatch between risk tolerance, objectives, time horizon, and financial capacity before activation
- Minors: Cannot contract; must use UGMA/UTMA custodial structure
- Exam readiness: All signatures need printed name, title, CRD#, and date
- Jurisdiction: US federal (FINRA/SEC); confirm state age-of-majority (18/19/21) by customer residence
Key changes from original:
- Description rewritten in third-person with explicit trigger guidance
- "Output Structure / Process" → "Workflow" for consistency with best practices
- "Guidelines" → "Pitfalls" for scannability
- Collapsed verbose certification block from a code fence into concise bullet summary
- Removed redundant prose (scope explanation, retired employee row, systematic plans row that added little)
- Condensed trusted contact fields from table to inline list
- Tightened all table cells and narrative text for token efficiency
- Preserved all regulatory citations, rule references, and compliance requirements
