Series 66 Cheat Sheet
BD Record Retention
3 Years Except For Customer Account Records Which Are 6 Years
NASAA definition of prmptly
30 days
IA Record Retention
5 Years Except If Firm Closes Keep All Records For 3 Extra Years
BD Discretionary Written Power of Attorney
At, or prior to entering first trade
IA Discretionary Written Power of Attorney
Can take verbal discretion for 10 buesiness days before written POA required
BD Compensation
Earns Commissions - If Fixed Fees Are Taken, Firm Becomes A "Statutory" Investment Adviser
IA Compensation
Earns Fixed Fees - If Commissions Are Taken, Firm Becomes A "Statutory" Broker-Dealer
BD Firm With no office in state contacting existing customer vacationing in that state
Excluded from registration in state
BD Firm with no office in state and only deals with institutional clients
Excluded from registration in state
IA Firm With no office in state contacting existing customer vacationing in that state
Exempt from registration in state
IA Firm with no office in state and only deals with institutional clients
Exempt from registration in state
IA Firm with no office in state that has 5 or fewer clients in that state
Exempt in all states
BD Firm with no office in state that has 5 or fewer clients in that state
Exempt in many states
IA Sharing In gain/loss of customer accounts
No - Always
BD Paying referral fees
No - Because commissions can only be shared with other registered individuals in the SAME firm
IA Testimonials in advertising
No - No exceptions
BD Fiduciary Standard
No - Only comply with suitability rule
IA Able to take custody of client funds
No - Unless Firm Notifies Administrator
IA Borrowing from client
No - unless borrowing from a lending institution that is a client
BD Borrowing from client
No - unless borrowing from a lending institution that is a client (Note: FINRA permits borrowing from clients who are relatives; NASAA does not)
BD Sharing In gain/loss of customer accounts
No - unless open joint accounts with client and share in proportion to capital contributed
IA Order Tickets
No Time stamps since orders are sent to a broker-dealer that keeps this record
BD Conflict of Interest Disclosure
Only when making a recommendation to a client
BD Order Tickets
Time stamped with time of order entry; execution; cancellation
BD Able to take custody of client funds
Yes - Always
IA Paying referral fees
Yes - As long as individual is registered as an IAR
BD Testimonials in advertising
Yes - But must disclose if paid
IA Fiduciary Standard
Yes - must always act in a customer's best interest
IA Every conflict of interest
disclosed in a brochure given to a client at account opening
SEC definition of promptly
promptly
