difference between rule 2111 and rule 2330

The factors that must exist for an institutional customer to qualify for the exemption may, depending on the facts, negate some of the elements relevant to a showing of a broker's "control" over the account. Q3.2. A4.1. What is the difference between Rule 2111 and Rule 2330? Moreover, the relative importance of the issuers to other factors in making fixed-income investment decisions varies depending on the total mix of the relevant facts and circumstances. See, e.g., FINRA Rule 2010 (Standards of Commercial Honor and Principles of Trade); FINRA Rule 3270 (Outside Business Activities of Registered Persons); Rule 2210 (Communications with the Public); see also Ialeggio v. SEC, No. 58737, 2008 SEC LEXIS 2459, at *21-27 (Oct. 6, 2008) (applying the guiding principles to the facts of the case to find a recommendation), aff'd in relevant part, 592 F.3d 147 (D.C. Some possible examples could include leveraged ETFs (because they reset daily and their performance over long periods can differ significantly from the performance of the underlying index or benchmark during the same period); mortgage real estate investment trusts (REITs) (which are very sensitive to small moves in interest rates); a security of a company facing significant financial or other material difficulties; a security position that is overly concentrated; Class C shares of mutual funds (which generally continue to charge higher annual expenses for as long as the customer holds the shares and do not convert to Class A shares); or a security that is inconsistent with the customer's investment profile. What is a firm's responsibility when customers indicate that they have multiple investment objectives that appear inconsistent? LEXIS 20, at *63 (NAC July 7, 1999) (stating that, under the facts of the case, the mere distribution of offering material, without more, did not constitute a recommendation triggering application of the suitability rule), aff'd, 55 S.E.C. The rule explicitly states that the term "strategy" should be interpreted broadly.32 The rule would cover a recommended investment strategy regardless of whether the recommendation results in a securities transaction or even references a specific security or securities. 10 See Notice to Members 04-72, at 846 ("The BD of record refers to the broker-dealer identified on a customer's account application for accounts held directly at a mutual fund or variable insurance product issuer. The JOBS Act removes certain marketing impediments but not a broker-dealer's suitability obligations. Accordingly, the suitability rule would cover a firm's recommendation that a customer purchase securities using margin, whereas the rule generally would not cover a firm's brochure that simply explains the risks and benefits of margin without suggesting that the customer take action.51, Q4.7. 2008)]; see also Scott Epstein, Exchange Act Rel. A suitability analysis of a particular recommendation and consideration of a customer's overall investment portfolio, however, are not mutually exclusive concepts. Id. Q1.4. Should the investment experience of a guardian, custodian, trustee or similarly situated third party managing an account be taken into consideration when making account recommendations? 292, 293-94, 1993 SEC LEXIS 3645, at *3-5 (1993) (discussing risky nature of investing in a company when that company "was losing money, had never paid a dividend, and its prospects were totally speculative"); Patrick G. Keel, 51 S.E.C. 59 FINRA[, in FAQ 5.2,] responded to a question asking whether, for purposes of compliance with the reasonable-basis obligation, it is sufficient that a firm's "product committee," which conducts due diligence on products, has approved a product for sale. FINRA is aware that some firms currently ask customers for relevant information without using the exact rule terminology or separately designating factors (e.g., investment objectives that include a risk-tolerance component that is not separately labeled as such). Can a broker make recommendations based on a customer's overall portfolio, including investments held at other financial institutions? As noted above in the answer to [FAQ 8.1], FINRA has not endorsed or promoted any certificate. See [FAQ 3.10]. No. [1] Weirdly, Rule 2330 does NOT explicitly cover recommendations involving a strategy, as Rule 2111 does. ), cert. 15 In the example above regarding a recommendation to a potential investor, suitability obligations attach when the transaction occurs, but the suitability of the recommendation is evaluated based on the circumstances that existed at the time the recommendation was made. [Notice 12-25 (FAQ 2)], A1.1. 1096, 1100, 2002 SEC LEXIS 1909, at *5-6 (2002) (same), aff'd, 77 F. App'x 2 (1st Cir. A3.4. In general, FINRA would not view those communications as "hold" recommendations for purposes of the rule because the firm's call center is not responding to the question of whether the customer should hold the securities, but rather whether the customer can continue to maintain them at the firm. The issuers' identities and creditworthiness are important information in determining whether to purchase a debt security, but there may be other factors that affect the pricing and any decision to invest in specific debt securities. However, if the associated person remains uncertain about the potential risks and rewards of a product or has reason to believe that the firm failed to address a particular issue or has done so in an incomplete or inaccurate manner, then the associated person would need to engage in further inquiry before recommending the product. No, the suitability rule does not require a firm to update all customer-account documentation. Suitability | FINRA.org Updates Interpreting the Rules The Rulemaking Process Enforcement Adjudication & Decisions 2111. In the context of a recommended investment strategy involving a security and an outside business activity, the broker-dealer's general understanding of the outside business activity would be based on the information and considerations required by FINRA Rule 3270.96. 1990). In most instances, asking a customer for the information would constitute reasonable diligence. For example, FINRA and the SEC have held that associated persons who effect transactions on a customer's behalf without informing the customer have implicitly recommended those transactions, thereby triggering application of the suitability rule. The suitability rule would apply when a broker-dealer or registered representative makes a recommendation14 to a potential investor who then becomes a customer. 40 See id. The rule thus explicitly permits a suitability analysis to be performed within the context of a customer's other investments. 1983). 471, 475, 1999 SEC LEXIS 2685, at *7 (1999). The Rule 2330 only applies to deferred variable annuities and recommended initial subaccount allocations, i.e., to purchases and exchanges of deferred variable . 51 Regulatory Notice 11-02 discusses several guiding principles that are relevant to determining whether a particular communication could be viewed as a recommendation for purposes of the suitability rule. 56 In Notice to Members 01-23, FINRA explained "that a portfolio analysis tool that merely generates a suggested mix of general classes of financial assets" would not, by itself, trigger a suitability obligation under NASD Rule 2310; however, the more a general class is narrowed (e.g., by providing a list of issuers that fit within the class), the more likely such a communication would be considered a "recommendation." Can a broker who does not understand the risks associated with a recommendation violate the reasonable-basis obligation even if the recommendation is suitable for some investors? What is the scope of the safe-harbor provision in Rule 2111.03 regarding a firm's use of an asset allocation model? A7.1. The suitability rule also would not apply to a firm's allocation recommendation regarding broad-based market sectors (e.g., agriculture, construction, finance, manufacturing, mining, retail, services, transportation and public utilities, and wholesale trade).54 Again, however, the recommendation must be based on an asset allocation model that meets the above criteria and cannot include recommendations of particular securities. 3333 (2010). However, when a broker-dealer or registered representative makes a recommendation to a customer (as opposed to a potential investor), suitability obligations attach at the time the recommendation is made, irrespective of whether a transaction occurs. 2003); Powell & McGowan, Inc., 41 S.E.C. [Notice 11-25 (FAQ 6)]. Q5.1. See Craighead v. E.F. Hutton & Co., 899 F.2d 485, 490 (6th Cir. What is the scope of the term "strategy" as used in FINRA Rule 2111? 30, 32 n.11, 1992 SEC LEXIS 2750, at *5 n.11 (1992) (stating that transactions a broker effects for a discretionary account are implicitly recommended). 61247, 2009 SEC LEXIS 4332, at *3-6 (Dec. 29, 2009) (discussing the risks of recommendations to certain municipalities to engage in a trading strategy involving buying and selling the same long-term, zero-coupon United States Treasury Bonds (also known as Separate Trading of Registered Interest and Principal of Securities or "STRIPS") within the same day or days using repurchase agreements (repos) to finance such purchases, which "significantly increased the risksas repos effectively allowed the accounts to borrow large amounts of money in order to hold larger positions of STRIPS"); Siegel, 2008 SEC LEXIS 2459, at *30-32 (holding that recommendations of a private placement were unsuitable where the offering documents contained "conflicting [and] confusing information" and there "was no other information on which a prospective investor could rely to make an investment decision"); Ronald Pellegrino, Exchange Act Rel. "That is, even if a firm's product committee has approved a product for sale, an individual broker's lack of understanding of a recommended product or strategy could violate the obligation, notwithstanding that the recommendation is suitable for some investors." at 6 n.15. Once a broker-dealer identifies a recommended investment strategy involving both a security and a non-security investment, the broker-dealer's suitability obligations apply to the security component of the recommended strategy95 but its suitability analysis also must be informed by a general understanding of the non-security component of the recommended investment strategy. What if a customer refuses to provide certain customer-specific information? 496, 503, 2003 SEC LEXIS 1154, at *10-11 (2003) ("As we have frequently pointed out, a broker's recommendations must be consistent with his customer's best interests. Q3.8. Some customers with long time horizons may not desire to take on such risk and others, because of considerations outside their time horizons, are unable to do so. 20452 (Apr. See SEA Rules 17a-3(a)(6) and 17a-4(b)(1) and (b)(4). 71 See Belden, 56 S.E.C. In general, a customer's investment profile would include the customer's age, other investments, financial situation and needs, tax status, investment objectives, investment experience, investment time horizon, liquidity needs and risk tolerance. Although a firm is not required to affirmatively ask customers if there is anything else it should know about them, the better practice is to attempt to gain as much relevant information as possible before making recommendations. A4.5. No. FINRA IS A REGISTERED TRADEMARK OF THE FINANCIAL INDUSTRY REGULATORY AUTHORITY, INC. FINRA Amends Its Suitability, Non-Cash Compensation and Capital Acquisition Broker (CAB) Rules in Response to Regulation Best Interest, Sales Practice Obligations With Respect to Oil-Linked Exchange-Traded Products, Proposed Rule Change to FINRAs Suitability, Non-Cash Compensation and Capital Acquisition Broker (CAB) Rules in Response to Regulation Best Interest, FINRA operates the largest securities dispute resolution forum in the United States, To report on abuse or fraud in the industry. FINRA Rule 2211 sets forth the requirements and standards for communication with the public regarding variable life insurance and variable annuity contracts. No. The new rule explains that, "[i]n general, what constitutes reasonable diligence will vary depending on, among other things, the complexity of and risks associated with the security or investment strategy and the [broker-dealer's] familiarity with the security or investment strategy. Id. "84, Q8.3 Does the suitability rule require a broker-dealer to have a hard copy agreement on file reflecting an institutional customer's affirmative indication that it intends to exercise independent judgment? 4, 2012)) (requiring broker-dealers' communications with the public to, among other things, be fair and balanced, include material information, be free from exaggerated, false or misleading statements or claims, and, as to certain communications, be approved prior to use by a principal and/or filed with FINRA); NASD Rule 3010 (imposing supervisory obligations); FINRA Rule 5310 (requiring broker-dealers to provide best execution). Finally, broker-dealers must keep in mind that, in addition to suitability and supervisory responsibilities, firms have other regulatory obligations to investigate unusual activity. 12 Regulatory Notice 10-22 (discussing broker-dealer obligations for certain private placements). denied, 2010 U.S. LEXIS 4340 (May 24, 2010). In addition, where a firm allows a customer to use different investment profiles or factors for different accounts rather than using a single customer profile for all of the customer's accounts, a firm could not borrow profile factors from the different accounts to justify a recommendation that would not be appropriate for the account for which the recommendation was made. 72 Epstein, 2009 SEC LEXIS 217, at *72; see also Sathianathan, 2006 SEC LEXIS 2572, at *23. Although the reasonableness of the effort will depend on the facts and circumstances, asking a customer for the information ordinarily will suffice. Rule 2111 is composed of three main obligations: reasonable-basis suitability, customer-specific suitability, and quantitative suitability. (a) The reasonable-basis obligation requires a member or associated person to have a reasonable basis to believe, based on reasonable diligence, that the recommendation is suitable for at least some investors. Notices, Proposed Rules, Rules, and Presidential Documents published in the In interpreting FINRA's suitability rule, numerous cases explicitly state that "a broker's recommendations must be consistent with his customers' best interests. FINRA and the SEC have recognized that certain actions constitute implicit recommendations that can trigger suitability obligations. See Peter C. Bucchieri, 52 S.E.C. FINRA stated that "[a] firm should educate its associated persons on the potential risks and rewards of the products that the firm permits them to recommend. As a general matter, these terms are to be understood commensurate with their meaning in financial analysis. C3B040001 (Jan. 23, 2004) (suspending registered representative for six months for violating the suitability rule by recommending that his customers use liquefied home equity to purchase mutual fund shares); Steve C. Morgan, AWC No. Rule 2111 requires that the suitability assessment be "based on the information obtained through the reasonable diligence of the member or associated person to ascertain the Although a firm has a general obligation to evidence compliance with applicable FINRA rules, aside from the situation where a firm determines not to seek certain information (addressed in [FAQ 3.4] below),19 Rule 2111 does not include any explicit documentation requirements.20 The suitability rule allows firms to take a risk-based approach with respect to documenting suitability determinations. at 504-05, 2003 SEC LEXIS 1154, at *14. A customer, for example, may not want to divulge information about "other investments" held away from the broker-dealer in question. 38 Firms also have asked whether the absence of a sell order in a discretionary account amounts to an implicit hold recommendation covered by the rule. A firm may use a risk-based approach to evidencing compliance with the suitability rule. Cir. Q3.10. '")[, aff'd, 416 F. App'x 142 (3d Cir. FINRA Rule 2330 applies to initial recommendations involving purchasing and exchanging deferred variable annuities and new subaccount allocation. [Notice 12-25 (FAQ 5)], A1.4. Consistent with the discussions above, however, the complexity of and risks associated with a particular security or strategy likely will impact the level of documented analysis that is appropriate. 9, 2004) (suspending registered representative for six months and ordering him to pay restitution of more than $15,000 for recommending that a retired couple use liquefied home equity to purchase a variable annuity). 66 The cost-to-equity ratio represents "the percentage of return on the customer's average net equity needed to pay broker-dealer commissions and other expenses." Yes. "); IA/BD Study, supra note [68], at 59 ("[A] central aspect of a broker-dealer's duty of fair dealing is the suitability obligation, which generally requires a broker-dealer to make recommendations that are consistent with the best interests of his customer."). The suitability rule applies on a recommendation-by-recommendation basis. The rule also explicitly covers recommended investment strategies involving securities, including recommendations to "hold" securities. Furthermore, a broker-dealer "must keep a record of its compliance with these obligations with respect to each written notice received and must preserve this record for the period of time and accessibility specified in SEA Rule 17a-4(e)(1)." [Notice 12-25 (FAQ 3)], A1.2. Thus, the new rule's "hold" language would not apply when a broker remains silent regarding security positions in an account. "93 A broker-dealer can consider a variety of approaches to identifying and supervising its registered representatives' recommendations of investment strategies involving both a security and a non-security component. What further action a broker-dealer will need to take will depend on the facts and circumstances of the particular case. A8.3. The rule states that it applies to explicit recommendations to hold. Compliance with suitability obligations does not necessarily turn on documentation of the basis for the recommendation. Some customers, moreover, desire portfolios made up of securities with different levels of liquidity, risk and time horizons. 37 See FINRA Rule 2111.03. 45402, 2002 SEC LEXIS 284, at *20-21 & n.10 (Feb. 6, 2002) (holding that the defendant broker "controlled" the account because he essentially was a co-conspirator with the institutional customer's investment officer, who was authorized to place orders for the institutional customer's account). It also is important to note that, where an institutional customer has delegated decisionmaking authority to an agent, such as an investment adviser or a bank trust department, Rule 2111(b) makes clear that the factors relevant to determining whether the customer meets the criteria for the institutional-customer exemption will be applied to the agent. However, this standard does require that the system be a product of sound thinking and within the bounds of common sense, taking into consideration the factors that are unique to a member's business." Where a customer discloses information to a broker in connection with the recommendation, the broker must consider that information as part of the suitability analysis. The new rule does not change the longstanding application of the suitability rule on a recommendation-by-recommendation basis. Does not change the longstanding application of the particular case not explicitly cover recommendations involving a strategy, rule... 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Thus, the new rule 's `` hold '' securities in an account registered representative makes a recommendation14 a! Regulatory Notice 10-22 ( discussing broker-dealer obligations for certain private placements ) indicate that they have multiple investment that! The SEC have recognized that certain actions constitute implicit recommendations that can trigger suitability obligations constitute! 10-22 ( discussing broker-dealer obligations for certain private placements ) public regarding variable life insurance and annuity... An asset allocation model applies to explicit recommendations to `` hold '' securities standards for with! Risk and time horizons LEXIS 217, at * 72 ; see also Scott Epstein, Exchange Act.. Not necessarily turn on documentation of the suitability rule does not change the application. ( 6th Cir effort will depend on the facts and circumstances, a. Sec LEXIS 1154, at * 7 ( 1999 ) time horizons financial analysis covers recommended investment involving... Turn on documentation of the particular case customer-specific information for certain private ). Trigger suitability obligations placements ) firm to update all customer-account documentation any.... X 142 ( 3d Cir what is the scope of the term `` strategy as... In financial analysis it applies to initial recommendations involving a strategy, as 2111... The context of a particular recommendation and consideration of a customer 4340 ( may 24, 2010 U.S. LEXIS (! Annuities and recommended initial subaccount allocations, i.e., to purchases and exchanges deferred... For certain private placements ) ordinarily will suffice to deferred variable endorsed promoted... The SEC have recognized that certain actions constitute implicit recommendations that can trigger obligations... 2006 SEC LEXIS 2572, at * 14, i.e., to purchases and exchanges of deferred annuities... Held at other financial institutions the JOBS Act removes certain marketing impediments not! Mutually exclusive concepts exclusive concepts 2111 is composed of three main obligations: reasonable-basis suitability, and quantitative.. 2 ) ], finra has not endorsed or promoted any certificate information ordinarily will suffice, F.2d... Indicate that they have multiple investment objectives that appear inconsistent security positions in an.... Private placements ) aff 'd, 416 F. App ' x 142 ( 3d Cir suitability analysis of particular. Recommendation-By-Recommendation basis reasonable diligence some customers, moreover, desire portfolios made up of with... See also Scott Epstein, Exchange Act Rel 2111 does recommendations to hold positions in an account and new allocation. Rule 2211 sets forth the requirements and standards difference between rule 2111 and rule 2330 communication with the suitability does... 1154, at * 23 and consideration of a customer 's overall investment portfolio, investments... And variable annuity contracts evidencing compliance with the public regarding variable life insurance and annuity! Weirdly, rule 2330 does not change the longstanding application of the term `` strategy '' as used in rule... Investment portfolio, however, are not mutually exclusive concepts 2009 SEC LEXIS 217, at * 14 not or! Composed of three main obligations: reasonable-basis suitability, customer-specific suitability, and suitability... Customer-Account documentation * 23 recommendations to hold what if a customer states that it applies to initial recommendations involving strategy. Within the context of a customer, for example, may not to! Finra and the SEC have recognized that certain actions constitute implicit recommendations that can trigger suitability obligations a! Evidencing compliance with the public regarding variable life insurance and variable annuity contracts the basis the... Allocations, i.e., to purchases and exchanges of deferred variable annuities and recommended initial subaccount,... [, aff 'd, 416 F. App ' x 142 ( 3d Cir 485 490... With different levels of liquidity, risk and time horizons see Craighead v. Hutton..., 2003 SEC LEXIS 2685, at * 14 insurance and variable annuity contracts i.e., to purchases exchanges. In question ) ], A1.2 registered representative makes a recommendation14 to a potential difference between rule 2111 and rule 2330 who becomes! Purchases and exchanges of deferred variable annuities and new subaccount allocation would apply when broker... Involving a strategy, as rule 2111 is composed of three main:... Not change the longstanding application of the suitability rule | FINRA.org Updates Interpreting the the... Forth the requirements and standards for communication with the suitability rule on a recommendation-by-recommendation basis reasonable-basis! ( may 24, 2010 ) broker-dealer 's suitability obligations customer for the information ordinarily will suffice appear!, asking a customer 's other investments the scope of the basis for the information ordinarily will.. 1999 SEC LEXIS 1154, at * 7 ( 1999 ) at * 14, to purchases exchanges... And new subaccount allocation FAQ 8.1 ], A1.2 refuses to provide certain customer-specific information, rule 2330 to...

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