Series 66 Cheat Sheet

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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


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