Series 14: Sales Solicitations

Series 14 Sales Solicitations questions help you isolate one part of the FINRA outline before returning to a mixed practice test. The questions below are original Securities Prep practice items aligned to this topic and are not copied from any exam sponsor.

Topic snapshot

Sample questions

Question 1

A social-media surveillance alert flags a scheduled LinkedIn post from a registered rep on the firm’s approved page.

Draft post (scheduled): “Unbiased newsletter nails it again. We agree—ABC is a strong buy. DM me.” (Attached image: screenshot of an unaffiliated market newsletter recommending ABC)

The rep says, “It’s third-party content, so it doesn’t need our approval.” As the compliance official, what is the best next step in the correct workflow sequence?

• A. Publish now and sample it in the next periodic review
• B. Allow the post because the newsletter is unaffiliated
• C. Stop the post and route it for principal review/retention
• D. Allow the post if it includes a third-party disclaimer

Best answer: C

Explanation: By endorsing and republishing the newsletter, the firm has adopted the content, so it must be treated as a firm retail communication subject to approval and recordkeeping.

The rep’s caption endorses and republishes third-party content, creating adoption (and potential entanglement) risk. That makes the combined message a firm communication the firm is responsible for, so the correct next step is to halt distribution and submit it to the firm’s communications-approval and records process before any use.

When a firm or its associated person republishes, links with commentary, or otherwise endorses third-party material, the firm can “adopt” that content and becomes responsible for it as if the firm created it. Using a screenshot plus an affirmative statement like “we agree—strong buy” is a classic adoption indicator because the rep is incorporating the third-party recommendation into a firm message.

In a compliant workflow, the sequence is to prevent distribution, capture/retain the proposed content, and send it through the firm’s required communications review (including principal approval where applicable). Only after review can the firm decide whether to revise (e.g., remove endorsement, add required context/disclosures) or prohibit use. Disclaimers or publisher reputation do not negate adoption created by endorsement.

• Disclaimer cures it fails because endorsement can still make the firm responsible for the content.
• Unaffiliated source is not sufficient; republishing with commentary can be adoption.
• Post then review is the wrong order when pre-use controls are required by the firm’s process for this type of communication.

Question 2

A registered representative sends the same product-update email to 8 retail customers over a two-week period. Which supervisory treatment best matches this message under FINRA public communications standards?

• A. Post-use review under risk-based written procedures
• B. Registered principal pre-use approval is required
• C. No principal review is required if recipients are existing customers
• D. Filing with FINRA prior to use is required

Best answer: A

Explanation: Because it is distributed to 25 or fewer retail investors in 30 days, it is correspondence, which is typically supervised through post-use review under WSPs.

A message sent to 25 or fewer retail investors within a 30-calendar-day period is generally treated as correspondence. Correspondence does not require registered principal pre-use approval, but it must be supervised and reviewed under the firm’s written, risk-based procedures. Here, the 8-recipient email fits correspondence, so post-use review is the best match.

The key supervision decision is driven by how the communication is classified. Retail communications (broad distribution to retail investors) generally require a registered principal’s approval before first use. Correspondence, however, is more limited distribution to retail investors (typically 25 or fewer within a 30-calendar-day period) and is supervised through the firm’s written supervisory procedures, commonly using post-use, risk-based review rather than mandatory pre-use sign-off.

Because this email goes to only 8 retail customers over two weeks, it falls into the correspondence bucket, so the appropriate control is documented, risk-based post-use supervision (with escalation for red flags), not blanket pre-use principal approval.

• Pre-use approval default applies to retail communications with broader retail distribution, not limited-recipient correspondence.
• Existing-customer carve-out is not a general exemption; correspondence still requires supervisory review under WSPs.
• FINRA filing requirement applies only to specific filing obligations and is not triggered simply by sending limited-recipient correspondence.

Question 3

Which statement is most accurate about a broker-dealer’s record-retention expectations for public communications regarding versions, approvals, and supporting evidence?

• A. Firms should retain each distributed version, approval evidence, and claim support.
• B. Approvals may be documented orally if supervision is otherwise adequate.
• C. Supporting documentation is not required if the communication is balanced.
• D. Only the final, most current version must be retained.

Best answer: A

Explanation: Records should allow the firm to show what was actually used, who approved it and when, and the basis for any statements or claims.

Compliance must be able to evidence what communication was actually used, that it was properly approved, and that any statements in it were supportable at the time of use. That requires retaining the version(s) distributed or posted, the approving principal’s identity/date, and the backup materials for claims. This is what makes the firm’s supervision defensible in an exam or investigation.

For public communications, recordkeeping is not just “keep a copy.” A firm should be able to recreate what investors saw and demonstrate supervisory approval and substantiation. Practically, that means retaining (1) the actual version(s) that were distributed or posted (and each materially changed version that is used), (2) evidence of required approvals (who approved and when), and (3) the supporting documentation for claims, comparisons, performance, or other factual assertions (e.g., sources, calculations, and back-up). Keeping only the latest version, relying on undocumented oral approvals, or treating substantiation as optional undermines the firm’s ability to prove compliant review and a reasonable basis for statements.

• Keep only the latest version fails because prior distributed/posted versions may need to be produced with their approval history.
• Oral approval is enough fails because the firm needs retained evidence of approval (who/when) to demonstrate supervision.
• No support needed if “balanced” fails because firms must retain backup that substantiates factual statements and claims.

Question 4

A registered rep drafts a product email and gets it approved in the firm’s communications review system. After approval, the rep “tightens the language” in Outlook, updates a performance chart, and sends the email blast to retail customers. During a FINRA exam, Compliance can produce the originally approved draft, but the firm cannot retrieve the exact version that was sent, the final approval associated to that version, or the backup supporting the updated chart.

What is the PRIMARY compliance red flag/control concern?

• A. Increased risk of manipulative conduct due to promotional timing
• B. Missing customer-by-customer suitability documentation for recipients
• C. No retained final version and approval evidence for distribution
• D. OFAC screening was not performed on the email distribution list

Best answer: C

Explanation: Firms must be able to evidence what was actually distributed, who approved that exact version, and the supporting substantiation.

The key issue is records integrity for public communications: the firm must retain the actual distributed version, the approval trail for that specific version, and the substantiation/disclosure support for claims and graphics. If a rep edits content after approval and the firm cannot reproduce what was sent, supervision and regulatory recordkeeping become indefensible. The control gap is the inability to link distribution to an approved, supported version.

For communications with the public, a firm’s supervision must be supported by defensible records that show (1) the content actually disseminated, (2) the associated approval(s) for that exact content, and (3) the supporting evidence for any material statements, performance presentations, or graphics. When a rep modifies a message after it has been approved (including “minor” wording changes or updated charts), the final distributed version generally requires capture and, as applicable under firm policy, re-approval; at minimum, the firm must be able to recreate the exact distributed content and the supervisory evidence tied to it. If Compliance can only produce an earlier draft, the firm cannot demonstrate effective review, cannot validate required disclosures, and cannot respond to regulator requests with complete records. The closest distractors describe other risks, but they do not address the core record-retention/approval-version control failure in the scenario.

• Suitability focus is secondary here because the scenario’s deficiency is version/approval/substantiation retention for the email itself.
• Manipulation timing is not implicated by facts about trading, pricing, or market activity.
• OFAC screening is not the primary control concern for a general marketing email absent sanctions-related triggers.

Question 5

A broker-dealer’s WSPs require a registered principal to approve retail communications before first use, but permit post-use principal review of correspondence and institutional communications through risk-based sampling.

Which statement about principal approval is INCORRECT?

Facts:

• A rep emails a product update to 10 retail customers in a 30-day period.

• Marketing posts a static PDF sales flyer on the firm’s public website.

• A sales trader sends Bloomberg chats to institutional accounts.

• A rep makes real-time, interactive social media replies (not static content).

• A. The Bloomberg chats must receive principal pre-use approval

• B. The interactive social media replies may be reviewed post-use as correspondence

• C. The static website PDF must be approved by a principal before first use

• D. The email to 10 retail customers may be reviewed post-use as correspondence

Best answer: A

Explanation: Institutional communications can be supervised through post-use review under written procedures rather than blanket pre-use approval.

Pre-use principal approval is generally required for retail communications (e.g., static website content), while correspondence and institutional communications may be subject to post-use principal review under reasonably designed WSPs. Institutional messages are typically supervised through review and surveillance rather than mandatory pre-approval. Here, requiring pre-use approval for all institutional Bloomberg chats is the incorrect statement.

FINRA’s communications framework ties the approval timing to the communication category. Retail communications (such as static marketing materials posted to a public website) generally require a registered principal’s approval before first use. By contrast, correspondence and institutional communications may be supervised through post-use review, often using risk-based sampling, as long as the firm’s written procedures are reasonably designed and a principal is responsible for the supervision.

Applied to these facts:

• Email sent to 10 retail customers in 30 days is correspondence, so post-use review can be appropriate.
• A static PDF on a public website is retail communication, so pre-use approval is required.
• Bloomberg chats to institutional accounts are institutional communications, so firms commonly supervise them via post-use review/surveillance rather than mandatory pre-use approval.
• Interactive social media replies are typically treated like correspondence and can be handled with post-use review.

The key is aligning the workflow (pre-use vs post-use) to the communication type and the firm’s WSPs.

• Over-approving institutional content is unnecessary because institutional communications can be supervised through post-use review under WSPs.
• Retail = pre-use is appropriate for static, broadly available website materials.
• Correspondence = post-use is generally acceptable when sent to 25 or fewer retail customers within 30 days.
• Interactive posts are typically treated as correspondence and fit post-use review models.

Question 6

A broker-dealer’s written telemarketing procedures (consistent with applicable telemarketing restrictions) permit outbound solicitation calls only between 8:00 a.m. and 9:00 p.m. in the customer’s local time and require immediate escalation of any written allegation of do-not-call (DNC) violations.

Exhibit: Complaint log (single row)

ComplaintID: 2026-00418
Received: Jan 8, 2026 10:14 ET
Channel: Email (from customer)
Allegation: "You called me again after I told you not to call."
Customer time zone: ET
Internal DNC flag: YES (added Dec 15, 2025)
Call record located: YES
Call timestamp: Jan 7, 2026 21:12 ET
Rep: J. Smith (RR)
Status: Pending review

Based on the exhibit, which interpretation is best supported for complaint intake and escalation supervision?

• A. This is not a complaint because it concerns telemarketing conduct rather than a securities transaction.
• B. This is a written DNC-related complaint that must be escalated because firm records show a call after the DNC flag and after 9:00 p.m. customer local time.
• C. This is not a written complaint because the customer did not submit a signed letter, so escalation is not required.
• D. This can be closed as unsubstantiated because the log does not confirm whether the customer is on the national DNC registry.

Best answer: B

Explanation: The email is a written complaint and the log corroborates both a post-DNC contact and an after-hours call, triggering escalation under the firm’s procedures.

The customer’s email is a written grievance about solicitation conduct, so it meets the threshold for complaint intake controls. The firm’s own records show the customer was already flagged internal DNC and that a solicitation call occurred at 9:12 p.m. in the customer’s time zone, which the procedures prohibit. Those documented facts support immediate escalation for investigation and remediation.

Complaint supervision starts with accurate intake and timely escalation of written allegations, including those about telemarketing practices. Here, the channel is email, so it is a written complaint for firm tracking and review. The exhibit also provides two objective data points that align with the allegation: an internal DNC flag was added before the call, and the call occurred at 21:12 ET, which is after the firm’s permitted calling window for an ET customer. A compliance-appropriate interpretation is that the matter must be escalated under the firm’s procedures, with a documented investigation (e.g., preserve the call record/recording, confirm the dialing source/list, assess supervision and training, and remediate to prevent recurrence). The national DNC status is not needed to support escalation when the firm’s internal DNC and time-of-day controls appear to have failed.

• Transaction-only misconception fails because complaints can involve solicitation conduct by the firm or associated persons.
• Signature requirement fails because written complaints include emails and other written electronic communications.
• National DNC dependency fails because the exhibit already supports escalation based on internal DNC and after-hours calling.

Question 7

A broker-dealer’s monthly telemarketing exception report shows a repeating pattern across two branches: (1) calls placed to numbers flagged as “Do-Not-Call (DNC)” in the firm CRM, (2) calls placed outside the customer’s local permitted calling window captured in the CRM profile, and (3) missing call recordings for a subset of outbound calls. The branch manager has “reminded reps to be careful,” but exceptions continue.

As the compliance officer, which remediation action best aligns with durable supervisory standards for telephone solicitations?

• A. Discipline involved reps and close alerts once sanctions are issued
• B. Issue a firmwide memo and require annual telemarketing training
• C. Outsource outbound calls to a vendor and rely on its policies
• D. Add dialer controls, DNC scrubbing, and supervisor exception workflow

Best answer: D

Explanation: It hardens prevention with system gating and adds documented supervisory review and follow-up for residual exceptions.

Repeated exceptions indicate a control weakness, not a knowledge gap. The most durable remediation combines preventative technology (pre-dial DNC and time-zone gating and recording capture) with a documented supervisory workflow to investigate, remediate, and trend issues. That approach creates accountable oversight and evidence of effective supervision.

When the same telemarketing exceptions recur, supervision should shift from reminders to a control-driven remediation plan that prevents issues and proves oversight. Here, controls should stop prohibited calls before they occur (e.g., automated DNC scrubs against internal opt-outs and configured calling-window checks using the customer’s local time) and ensure required records are captured (recording/retention with exception flags when missing). Just as important, supervision must include an exception-management workflow: alerts routed to a designated supervisor, documented investigation and root-cause analysis (rep behavior, list hygiene, dialer configuration, vendor routing), corrective actions, and trend reporting to confirm the fix is working. Training and discipline can support the plan, but they do not substitute for preventative gating, reliable record capture, and accountable follow-up that addresses systemic failures.

The key takeaway is to pair technology-based prevention with documented supervisory accountability and monitoring.

• Training-only fix doesn’t address list scrubbing, time-zone logic, or recording capture failures.
• Discipline-only response treats symptoms and can leave the broken process and missing records unchanged.
• Vendor reliance still requires firm supervision and evidence that DNC, time windows, and recordings are controlled.

Question 8

A broker-dealer is updating its digital-communications WSPs. (1) Marketing uploads a firm-written product page to the public website that remains unchanged until the next scheduled revision. (2) Registered reps respond in real time to prospect questions through a website live-chat widget, and all chat transcripts are captured and archived.

Which option correctly matches each item to the communication type and the firm’s most appropriate monitoring method?

• A. Both are interactive and may be supervised only by annual attestations from reps
• B. Product page is static and should be principal pre-approved; live chat is interactive and should be supervised through risk-based post-use review/surveillance
• C. Both are static and must be principal pre-approved before any use
• D. Product page is interactive and should be reviewed after use; live chat is static and must be principal pre-approved

Best answer: B

Explanation: Static retail content is typically approved before first use, while interactive chat is generally supervised via post-use monitoring with retained records.

A website page that stays the same until edited is static content, so the key control is principal approval before first use (and periodic review thereafter). A live-chat stream is interactive because the content is created in real time, so supervision is typically accomplished through documented, risk-based post-use review and electronic surveillance of captured transcripts.

The decisive difference is whether the message is a fixed piece of content or a real-time, back-and-forth exchange. Static content (like an unchanged website product page) functions like a traditional advertisement: it can be reviewed in full before it goes live, so a strong supervisory control is principal pre-use approval with subsequent periodic reviews/updates. Interactive communications (like a live-chat widget) generate content dynamically and at high volume, making pre-approval of each message impractical; the defensible approach is to retain the records and apply documented, risk-based post-use supervision (e.g., lexicon or keyword surveillance, sampling, escalation and investigation of flagged items, and trending/reporting). The key is matching the monitoring method to how the content is produced and updated.

• Inverting static vs interactive misclassifies the website page as real-time content and the live chat as fixed content.
• Treating both as static overstates pre-use approval by ignoring that interactive chat is created on the fly.
• Relying on attestations only is not a monitoring method and does not evidence review of captured interactive communications.

Question 9

A broker-dealer launches a centralized outbound cold-calling campaign using a third-party dialer to solicit retail customers in multiple states. The firm sets a calling window of 9:00 a.m.–6:00 p.m. Eastern time for all calls, and the vendor scrubs numbers against the National Do Not Call Registry only once per week. Branches maintain their own “do-not-call” opt-out notes, but those opt-outs are not fed to the dialer.

A prospect in California who previously told a registered representative “do not call me again” is called at 6:30 a.m. Pacific time (9:30 a.m. Eastern) and files a complaint.

What is the most likely outcome for the firm if these controls are not promptly corrected?

• A. Minimal exposure since weekly National DNC scrubs are sufficient
• B. Heightened FINRA and FCC/TCPA risk requiring remediation and documentation
• C. Only SEC advertising rules apply; telemarketing controls are not implicated
• D. Exposure is limited to state law because FINRA has no DNC expectations

Best answer: B

Explanation: The facts show failures to honor firm-specific do-not-call requests and local-time calling expectations, creating both supervisory findings and telemarketing enforcement exposure.

Using a single Eastern-time calling window and failing to operationalize firm-specific opt-outs makes it likely the firm will place prohibited calls in customers’ local time zones and ignore do-not-call requests. That combination typically results in supervisory deficiencies under FINRA expectations and telemarketing enforcement exposure under FCC/TCPA frameworks, requiring prompt corrective action and documented follow-up.

In multi-jurisdiction solicitation programs, firms must coordinate vendor dialing practices with both FINRA supervisory expectations (written procedures, training, evidence of review, and honoring internal do-not-call requests) and FCC/TCPA-style telemarketing expectations (including honoring do-not-call requests and managing time-of-day calling based on the called party’s local time). Here, the complaint arises from two control gaps: opt-out requests are not centralized into a firm do-not-call mechanism, and the calling window is not aligned to local time for West Coast recipients. The most likely consequence is increased regulatory exposure and an expectation of prompt remediation with defensible records, such as:

• Immediately adding the number to a centralized do-not-call list used by the dialer
• Adjusting dialing controls to apply local-time calling windows
• Increasing scrub frequency and reconciling vendor outputs to firm records
• Documenting the investigation, remediation, and supervisory follow-up

A National DNC scrub alone does not substitute for firm-specific opt-outs and time-zone controls.

• National DNC alone misses firm-specific opt-out obligations and time-zone controls.
• Wrong rule set is incorrect because telemarketing rules, not just advertising, drive the consequence.
• “FINRA not involved” fails because FINRA examines supervision and procedures for solicitation activity.
• Outcome framing is correct because it captures both supervisory findings and telemarketing enforcement risk.

Question 10

You oversee the retail options business line’s social-media and email marketing review program, which must support a 24-hour turnaround for marketing approvals. Over the last two months, your metrics show a rising exception trend (posts requiring compliance edits increased from 6% to 18%) and a higher rework rate (average revisions per item increased from 0.4 to 1.3). A recent FINRA exam finding also cited missing evidence of required principal approval for several influencer posts, and management expects a corrective action plan within 30 days. Which compliance action best measures program effectiveness while minimizing regulatory risk?

• A. Let marketing self-approve and rely on quarterly compliance spot-checks
• B. Suspend all campaigns until every item receives pre-use principal review
• C. Keep current sampling and send a general reminder about disclosures
• D. Document root-cause; redesign workflow using exception/rework trends; report to CCO

Best answer: D

Explanation: This uses KPI trend and exam data to drive documented, escalated, risk-based remediation that can be validated with follow-up metrics.

Effective measurement ties operational indicators (exceptions and rework) to root-cause analysis and to objective outcomes (reduced exceptions and clean approval evidence) after remediation. The best response documents what is failing, adjusts controls to address the failure points, and escalates a time-bound corrective plan that can be tracked with the same metrics. This approach both improves compliance quality and creates defensible supervisory evidence.

When exception and rework rates rise and a regulator cites missing approval evidence, the compliance risk is both content risk (deficient communications) and process risk (ineffective approval/recordkeeping). Measuring program effectiveness means converting those signals into a documented root-cause assessment (e.g., unclear content standards, weak workflow controls, or poor evidence capture), then implementing specific control changes that can be validated by tracking the same KPIs over time.

A strong corrective action plan typically includes:

• KPI-based diagnosis (exceptions, rework, turnaround time, repeat offenders)
• Workflow fixes (required approval steps, evidence capture, standardized templates)
• Targeted training and accountability for the drivers of exceptions
• Escalation and governance (CCO/senior management reporting and closure testing)

A blanket shutdown or vague reminders do not demonstrate an effective, measurable supervisory response to the trends and the exam finding.

• Blanket shutdown reduces output but may be unnecessary and conflicts with the 24-hour turnaround constraint.
• Reminder-only does not address missing approval evidence or provide measurable remediation beyond hoping rates improve.
• Self-approval with spot-checks weakens supervisory controls and does not remediate the cited approval-evidence failure.

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