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Introduction
1. Supervision
2. Registrations
2.1 Introduction to registrations
2.2 Registration categories
2.3 Securities registration exemptions
3. Client issues
4. Investment products
5. Margin accounts
6. Federal rules and regulations
Wrapping up
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2.2 Registration categories
Achievable Series 10
2. Registrations
Our FINRA Series 10 course is currently in development and is a work-in-progress.

Registration categories

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Registration definitions

Registered representatives

Persons wishing to work with a member firm in investment banking or securities, in roles such as supervision, solicitation, conduct of business, or train persons, will need to be registered as a representative in each category of registration appropriate to their functions and responsibilities. Examples would be; Investment Companies, Equity, Debt, DPPs, and similar individual lines of securities.

Registered principals

Principals supervise other associated persons. Depending on what they are supervising, principals will need to be registered as principals in each category of registration appropriate to their functions and responsibilities. The list of examples would be the same as above.

Every member with more than 1 associated person, must have at least 2 officers or partners that are registered for supervision of the firm’s business. Offices with only 1 associated person are a weird situation, and don’t really exist in the real world.

Registration categories

Principal registrations

Any person associated with a member in roles such as Sole Proprietor, Officer, Partner, Manager of an OSJ, director or similar role, or any other position engaged in the management of the members IB or securities business. Those positions being supervision, solicitation, conduct of securities business, training of associated persons. These include CEO and CFO.

General securities sales supervisor S9/10

Required for supervising sales in corporate/municipal securities, options, investment companies, variable contracts, and direct participation programs.

If the supervisory responsibilities in investment banking or securities are limited to securities sales activities of the member, including approval of accounts, training of sales and sales supervisory people, and maintaining records of original entry or ledgers. These original entry records shall be maintained at brach offices by Exchange Act record keeping rules.

A General Securities Sales Supervisor may not perform the following;

  • Supervision of origination and structuring of underwritings,
  • Supervision of market making,
  • Supervision of custody of BD or customer funds, or
  • Supervision of overall compliance with financial responsibilities (Fin/Op Principal duties).

General securities principal S24

Covers multiple lines of business, and would not require multiple Principal Licenses. Included are Government, Investment Company and variable contracts, DPPs, or Private Offerings. Multiple licenses would be required if duties include; Functioning as a Compliance Officer, a Fin/Op Principal, or BD Fin/Op Principal, Principal Financial Officer, Principal Operations Officer, Investment Banking Principal, Research Principal, Securities Trader Principal, or Registered Options Principal.

Ultimately responsible for approving general securities accounts, the transactions in them, and supervising of equity traders.

Financial and operations principal and introducing broker-dealer financial and operations principal S27/28

Each firm must designate a Fin/Op Principal or a BD Fin/Op Principal. For companies that don’t have full lines of business, and are simply introducing broker dealers, than they would only need an introducing broker-dealer financial and operations principal. Duties;

  • Final approval and responsibility of financial reports submitted,
  • Final preparation of said reports,
  • Supervisions of individuals preparing said report,
  • Supervision and responsibility for everyone involved in the maintenance of members books and records,
  • Supervision and performance of members responsibilities under all financial responsibility rules and regulations,
  • Overall supervision and responsibility of everyone involved in the administration and maintenance of back office operations, and
  • Any other matter involving financial or operational management of the member.

Ultimately responsible for managing recordkeeping and financial reporting

Registered options principal S4

Each member engaging in options transactions must have at least one Registered Options Principal. They supervise member’s options sales practices with the public. They are responsible for approving opening of options accounts, transactions, and communications regarding options.

Government securities principal

Required the activities include; Underwriting, trading, or selling government securities, Financial advisory or consultant services for issuers in connection to government securities, Research or investment advice, other than generic, with respect to government securities, Activities involving communication (direct or indirect) with public investors in government securities, along with the supervision of processing and clearance activities with respect to government securities or maintenance of records involving these activities.

The series exam number is not needed.

Municipal Securities Sales Principal

This is a natural person, other than a full municipal securities principal, that is associated with the broker, the dealer, or the municipal securities dealer in question. There supervisory activities are limited to only supervising sales and purchases to and from customers, of municipal securities. None of the other supervisory activities of standard “full” principals.

To be a municipal securities sales principal, the person must pass the General Securities Sales Supervisor Qualification Exam, also known as the Series 9 and Series 10. Prior to being able to be qualified to be a municipal securities sales principal, the person must be duly qualified as either a municipal securities representative or a general securities representative. They could either be qualified for some other reason, or they simply could pass the exams, which would be the Series 52 or the Series 7.

The series exam number is not needed.

Municipal securities principal and municipal fund securities limited principal

Natural person associated with a broker, dealer, or municipal securities dealer, directly engaged in the management, direction, or supervision of municipal activities including;

  • Underwriting, trading, and sales of municipal securities
  • Advisory or consultant services in connection with the issuance of municipal securities
  • Research or advice on municipal securities
  • Activities with municipal securities involving communicating with public investors
  • Maintenance of records with respect to the above activities
  • Training of principals or representatives of the member

Municipal fund securities limited principal would do all of these type things, but only for municipal fund securities. Municipal fund securities, are those securities, that would be registered as investment companies, if they were not exempt from the investment company act of 1940 because they are municipal securities.

The series exam number is not needed.

Investment company and variable contracts products principal S26

Supervises opening of accounts, transactions in them, and communications limited to Investment Company and Variable Products.

Direct partnership programs principal S39

Supervises accounts, transactions and communications limited to Direct Partnership Programs.

Supervisory analyst S16

These are principals of the research analysts, and are ultimately responsible for preparing and approving research reports. Activities limited solely to approving Content of research reports on equity securities, Content of research reports on debt securities, Content of third-party research reports, Retail communications, or Other research communications not meeting the definition of “research report”.

Representative registrations

General securities representative S7

A registered Rep capable of selling most securities. If their job includes Operations Professional, Securities Trader, an IB Representative, or Research Analyst, they will need those licenses in addition to the Series 7. This license is required for most sales of securities to retail investors; corporate stocks/bonds, municipal/government securities, options, DPPs, ETFs, and all investment companies.

Operations professional S99

Senior management with serious responsibilities. Those responsibilities include, but are not limited to; Covered functions of the firm, Overseeing supervisors and principals, Ability to spend member’s capital in direct furtherance of covered functions.

Municipal securities representative and municipal securities sales limited representative S52

The full municipal securities representative, is a natural person that is associated with a broker, dealer, municipal securities dealer, in a position that is not solely clerical, ministerial, janitorial, or similar. Underwriting, advisory services, research, investment advice, and other activities involving communicating with public investors, would all define the person as a municipal securities representative.

A municipal securities sales limited representative, are limited exclusively to sales and purchases, to and from, customers of municipal securities. No underwriting, advisory, research, etc.

If the person is duly qualified as a general securities rep having taken the S7 prior to November 7, 2011 or if the person is trying to be a municipal limited rep and has the S7 at any time, or a person only selling municipal fund securities is duly qualified as a S6 rep, they would not need to take the S52.

Investment company and variable contracts products representative S6

The limited representative for investment company and variable contract products, is the series 6 representative. They are limited to selling and recommending transactions involving investment company and variable contracts. ETFs in their IPO, mutual funds at all times, are the most common investment company products, 529 college savings plans, and variable annuities and variable life would be the variable contracts.

Securities trader S57

Required for representatives who are executing/placing trades for clients, or are involved in market making.

Investment banking representative S79

Required for representatives, assisting clients in transactions, exclusively with investment banking products and services.

Research analyst S86/87

Not a selling license, this license is required to assist in the preparation of equity research reports.

Registered representatives

  • Must register in each relevant category based on job functions
  • Roles include supervision, solicitation, business conduct, training
  • Examples: Investment Companies, Equity, Debt, DPPs

Registered principals

  • Supervise associated persons; must register in each relevant category
  • Firms with >1 associated person need at least 2 registered officers/partners for supervision
  • Single-person offices are rare

Principal registrations

  • General securities sales supervisor S9/10

    • Supervises sales in corporate/municipal securities, options, investment companies, variable contracts, DPPs
    • Cannot supervise underwriting, market making, custody, or financial compliance
  • General securities principal S24

    • Covers multiple business lines; approves accounts and supervises equity traders
    • Additional licenses needed for compliance, Fin/Op, investment banking, research, trading, or options supervision
  • Financial and operations principal S27/28

    • Manages financial reports, recordkeeping, and back office operations
    • S27 for full-service firms; S28 for introducing broker-dealers
  • Registered options principal S4

    • Supervises options sales practices, account openings, transactions, and communications
  • Government securities principal

    • Supervises underwriting, trading, sales, advisory, research, and recordkeeping for government securities
  • Municipal Securities Sales Principal

    • Supervises only sales/purchases of municipal securities to/from customers
    • Must pass Series 9/10 and be qualified as municipal/general securities rep (S52 or S7)
  • Municipal securities principal & municipal fund securities limited principal

    • Supervises all municipal securities activities (underwriting, trading, advisory, research, records, training)
    • Limited principal: only for municipal fund securities
  • Investment company and variable contracts products principal S26

    • Supervises accounts, transactions, and communications for investment company/variable products
  • Direct partnership programs principal S39

    • Supervises accounts, transactions, and communications for DPPs
  • Supervisory analyst S16

    • Approves research reports and retail communications on equity/debt securities

Representative registrations

  • General securities representative S7

    • Can sell most securities (stocks, bonds, options, DPPs, ETFs, investment companies)
    • Additional licenses needed for operations, trading, IB, or research roles
  • Operations professional S99

    • Senior management overseeing covered firm functions, supervisors, principals, and capital expenditures
  • Municipal securities representative & municipal securities sales limited representative S52

    • Full rep: handles underwriting, advisory, research, sales, and communications for municipal securities
    • Limited rep: only sales/purchases to/from customers
    • S7 or S6 may substitute for S52 in some cases
  • Investment company and variable contracts products representative S6

    • Limited to selling investment company and variable contract products (mutual funds, ETFs in IPO, 529 plans, variable annuities/life)
  • Securities trader S57

    • Required for executing/placing trades or market making
  • Investment banking representative S79

    • Required for assisting clients with investment banking products/services
  • Research analyst S86/87

    • Required for preparing equity research reports (not a sales license)

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Registration categories

Registration definitions

Registered representatives

Persons wishing to work with a member firm in investment banking or securities, in roles such as supervision, solicitation, conduct of business, or train persons, will need to be registered as a representative in each category of registration appropriate to their functions and responsibilities. Examples would be; Investment Companies, Equity, Debt, DPPs, and similar individual lines of securities.

Registered principals

Principals supervise other associated persons. Depending on what they are supervising, principals will need to be registered as principals in each category of registration appropriate to their functions and responsibilities. The list of examples would be the same as above.

Every member with more than 1 associated person, must have at least 2 officers or partners that are registered for supervision of the firm’s business. Offices with only 1 associated person are a weird situation, and don’t really exist in the real world.

Registration categories

Principal registrations

Any person associated with a member in roles such as Sole Proprietor, Officer, Partner, Manager of an OSJ, director or similar role, or any other position engaged in the management of the members IB or securities business. Those positions being supervision, solicitation, conduct of securities business, training of associated persons. These include CEO and CFO.

General securities sales supervisor S9/10

Required for supervising sales in corporate/municipal securities, options, investment companies, variable contracts, and direct participation programs.

If the supervisory responsibilities in investment banking or securities are limited to securities sales activities of the member, including approval of accounts, training of sales and sales supervisory people, and maintaining records of original entry or ledgers. These original entry records shall be maintained at brach offices by Exchange Act record keeping rules.

A General Securities Sales Supervisor may not perform the following;

  • Supervision of origination and structuring of underwritings,
  • Supervision of market making,
  • Supervision of custody of BD or customer funds, or
  • Supervision of overall compliance with financial responsibilities (Fin/Op Principal duties).

General securities principal S24

Covers multiple lines of business, and would not require multiple Principal Licenses. Included are Government, Investment Company and variable contracts, DPPs, or Private Offerings. Multiple licenses would be required if duties include; Functioning as a Compliance Officer, a Fin/Op Principal, or BD Fin/Op Principal, Principal Financial Officer, Principal Operations Officer, Investment Banking Principal, Research Principal, Securities Trader Principal, or Registered Options Principal.

Ultimately responsible for approving general securities accounts, the transactions in them, and supervising of equity traders.

Financial and operations principal and introducing broker-dealer financial and operations principal S27/28

Each firm must designate a Fin/Op Principal or a BD Fin/Op Principal. For companies that don’t have full lines of business, and are simply introducing broker dealers, than they would only need an introducing broker-dealer financial and operations principal. Duties;

  • Final approval and responsibility of financial reports submitted,
  • Final preparation of said reports,
  • Supervisions of individuals preparing said report,
  • Supervision and responsibility for everyone involved in the maintenance of members books and records,
  • Supervision and performance of members responsibilities under all financial responsibility rules and regulations,
  • Overall supervision and responsibility of everyone involved in the administration and maintenance of back office operations, and
  • Any other matter involving financial or operational management of the member.

Ultimately responsible for managing recordkeeping and financial reporting

Registered options principal S4

Each member engaging in options transactions must have at least one Registered Options Principal. They supervise member’s options sales practices with the public. They are responsible for approving opening of options accounts, transactions, and communications regarding options.

Government securities principal

Required the activities include; Underwriting, trading, or selling government securities, Financial advisory or consultant services for issuers in connection to government securities, Research or investment advice, other than generic, with respect to government securities, Activities involving communication (direct or indirect) with public investors in government securities, along with the supervision of processing and clearance activities with respect to government securities or maintenance of records involving these activities.

The series exam number is not needed.

Municipal Securities Sales Principal

This is a natural person, other than a full municipal securities principal, that is associated with the broker, the dealer, or the municipal securities dealer in question. There supervisory activities are limited to only supervising sales and purchases to and from customers, of municipal securities. None of the other supervisory activities of standard “full” principals.

To be a municipal securities sales principal, the person must pass the General Securities Sales Supervisor Qualification Exam, also known as the Series 9 and Series 10. Prior to being able to be qualified to be a municipal securities sales principal, the person must be duly qualified as either a municipal securities representative or a general securities representative. They could either be qualified for some other reason, or they simply could pass the exams, which would be the Series 52 or the Series 7.

The series exam number is not needed.

Municipal securities principal and municipal fund securities limited principal

Natural person associated with a broker, dealer, or municipal securities dealer, directly engaged in the management, direction, or supervision of municipal activities including;

  • Underwriting, trading, and sales of municipal securities
  • Advisory or consultant services in connection with the issuance of municipal securities
  • Research or advice on municipal securities
  • Activities with municipal securities involving communicating with public investors
  • Maintenance of records with respect to the above activities
  • Training of principals or representatives of the member

Municipal fund securities limited principal would do all of these type things, but only for municipal fund securities. Municipal fund securities, are those securities, that would be registered as investment companies, if they were not exempt from the investment company act of 1940 because they are municipal securities.

The series exam number is not needed.

Investment company and variable contracts products principal S26

Supervises opening of accounts, transactions in them, and communications limited to Investment Company and Variable Products.

Direct partnership programs principal S39

Supervises accounts, transactions and communications limited to Direct Partnership Programs.

Supervisory analyst S16

These are principals of the research analysts, and are ultimately responsible for preparing and approving research reports. Activities limited solely to approving Content of research reports on equity securities, Content of research reports on debt securities, Content of third-party research reports, Retail communications, or Other research communications not meeting the definition of “research report”.

Representative registrations

General securities representative S7

A registered Rep capable of selling most securities. If their job includes Operations Professional, Securities Trader, an IB Representative, or Research Analyst, they will need those licenses in addition to the Series 7. This license is required for most sales of securities to retail investors; corporate stocks/bonds, municipal/government securities, options, DPPs, ETFs, and all investment companies.

Operations professional S99

Senior management with serious responsibilities. Those responsibilities include, but are not limited to; Covered functions of the firm, Overseeing supervisors and principals, Ability to spend member’s capital in direct furtherance of covered functions.

Municipal securities representative and municipal securities sales limited representative S52

The full municipal securities representative, is a natural person that is associated with a broker, dealer, municipal securities dealer, in a position that is not solely clerical, ministerial, janitorial, or similar. Underwriting, advisory services, research, investment advice, and other activities involving communicating with public investors, would all define the person as a municipal securities representative.

A municipal securities sales limited representative, are limited exclusively to sales and purchases, to and from, customers of municipal securities. No underwriting, advisory, research, etc.

If the person is duly qualified as a general securities rep having taken the S7 prior to November 7, 2011 or if the person is trying to be a municipal limited rep and has the S7 at any time, or a person only selling municipal fund securities is duly qualified as a S6 rep, they would not need to take the S52.

Investment company and variable contracts products representative S6

The limited representative for investment company and variable contract products, is the series 6 representative. They are limited to selling and recommending transactions involving investment company and variable contracts. ETFs in their IPO, mutual funds at all times, are the most common investment company products, 529 college savings plans, and variable annuities and variable life would be the variable contracts.

Securities trader S57

Required for representatives who are executing/placing trades for clients, or are involved in market making.

Investment banking representative S79

Required for representatives, assisting clients in transactions, exclusively with investment banking products and services.

Research analyst S86/87

Not a selling license, this license is required to assist in the preparation of equity research reports.

Key points

Registered representatives

  • Must register in each relevant category based on job functions
  • Roles include supervision, solicitation, business conduct, training
  • Examples: Investment Companies, Equity, Debt, DPPs

Registered principals

  • Supervise associated persons; must register in each relevant category
  • Firms with >1 associated person need at least 2 registered officers/partners for supervision
  • Single-person offices are rare

Principal registrations

  • General securities sales supervisor S9/10

    • Supervises sales in corporate/municipal securities, options, investment companies, variable contracts, DPPs
    • Cannot supervise underwriting, market making, custody, or financial compliance
  • General securities principal S24

    • Covers multiple business lines; approves accounts and supervises equity traders
    • Additional licenses needed for compliance, Fin/Op, investment banking, research, trading, or options supervision
  • Financial and operations principal S27/28

    • Manages financial reports, recordkeeping, and back office operations
    • S27 for full-service firms; S28 for introducing broker-dealers
  • Registered options principal S4

    • Supervises options sales practices, account openings, transactions, and communications
  • Government securities principal

    • Supervises underwriting, trading, sales, advisory, research, and recordkeeping for government securities
  • Municipal Securities Sales Principal

    • Supervises only sales/purchases of municipal securities to/from customers
    • Must pass Series 9/10 and be qualified as municipal/general securities rep (S52 or S7)
  • Municipal securities principal & municipal fund securities limited principal

    • Supervises all municipal securities activities (underwriting, trading, advisory, research, records, training)
    • Limited principal: only for municipal fund securities
  • Investment company and variable contracts products principal S26

    • Supervises accounts, transactions, and communications for investment company/variable products
  • Direct partnership programs principal S39

    • Supervises accounts, transactions, and communications for DPPs
  • Supervisory analyst S16

    • Approves research reports and retail communications on equity/debt securities

Representative registrations

  • General securities representative S7

    • Can sell most securities (stocks, bonds, options, DPPs, ETFs, investment companies)
    • Additional licenses needed for operations, trading, IB, or research roles
  • Operations professional S99

    • Senior management overseeing covered firm functions, supervisors, principals, and capital expenditures
  • Municipal securities representative & municipal securities sales limited representative S52

    • Full rep: handles underwriting, advisory, research, sales, and communications for municipal securities
    • Limited rep: only sales/purchases to/from customers
    • S7 or S6 may substitute for S52 in some cases
  • Investment company and variable contracts products representative S6

    • Limited to selling investment company and variable contract products (mutual funds, ETFs in IPO, 529 plans, variable annuities/life)
  • Securities trader S57

    • Required for executing/placing trades or market making
  • Investment banking representative S79

    • Required for assisting clients with investment banking products/services
  • Research analyst S86/87

    • Required for preparing equity research reports (not a sales license)