How to Use This Quick Reference
This independent Quick Reference is for candidates preparing for FINRA’s Series 23 — General Securities Principal Exam - Sales Supervisor Module, exam code Series 23. Use it as a final-pass checklist for supervisory judgment, rule distinctions, and scenario recognition.
For Series 23 questions, think like a principal:
- Prevent violations through written supervisory procedures, training, registration controls, and preapproval where required.
- Detect problems through reviews, exception reports, surveillance, branch inspections, and complaint analysis.
- Escalate and document red flags. A correct answer often includes evidence of follow-up, not just “reviewed.”
- Separate sales supervision from broader principal supervision: trading, market making, investment banking, research, communications, financial responsibility, and firm-level controls may be tested.
Supervisory Framework: High-Yield Map
| Area | Principal focus | Exam trigger |
|---|
| Registration and qualification | Proper registration before activity; Form U4/U5 accuracy; statutory disqualification controls | Unregistered person solicits, supervises, trades, or is paid transaction compensation |
| WSPs and supervisory system | Written procedures reasonably designed for the business; designated principals; evidence of review | “No one was assigned,” stale procedures, ignored exception reports |
| Branch and OSJ supervision | Office classification, inspections, remote supervision, escalation | Producing manager, distant branch, high-risk rep, customer complaints |
| Communications | Correct category, approval, filing if required, fair and balanced content | Social media post, seminar script, fund performance, promissory language |
| Customer accounts | CIP, KYC, trusted contact, account approval, suitability/Reg BI, discretionary authority | New account, senior investor, rollover, complex product recommendation |
| Sales practices | Gifts, borrowing/lending, sharing accounts, outside business activities, private securities transactions | Rep borrows from customer, sells private deal, guarantees loss |
| Trading and market making | Best execution, order handling, limit order protection, short sale rules, trade reporting | Firm trades ahead, ignores NBBO, mismarks order, late/corrected report |
| Investment banking and research | Due diligence, underwriting compensation, IPO allocation, Reg M, research conflicts | Analyst pressure, restricted persons, stabilization, quiet-period issue |
| Financial responsibility | Net capital awareness, customer protection, books and records, confirmations/statements | Customer funds misuse, inaccurate records, capital strain from new activity |
| AML and privacy | CIP, suspicious activity escalation, OFAC/sanctions controls, no tipping off, data safeguards | Structuring, unusual wires, third-party checks, privacy breach |
Core FINRA Supervision Rules and Concepts
| Topic | What to remember | Common trap |
|---|
| FINRA Rule 3110 supervision | Firm must establish and maintain a supervisory system reasonably designed to achieve compliance. WSPs must identify responsible supervisors and review steps. | “We had a manual” is not enough if no one followed it or procedures did not match the business. |
| FINRA Rule 3120 supervisory control testing | Firm must test and verify supervisory procedures and amend them when needed. | Annual testing cannot be a checklist exercise that ignores known failures. |
| FINRA Rule 3130 certification | Senior executive certification process requires review of compliance and supervisory systems. | Certification does not replace actual testing and remediation. |
| Branch inspections | OSJs and supervisory branches require more frequent inspection than non-supervisory locations. | A high-risk branch may require more attention than the minimum cycle. |
| Producing manager supervision | A manager who produces revenue must be supervised by someone with independence. | Allowing a producing manager to approve their own activity is a red flag. |
| Exception reports | Reports are tools; supervisors must review, investigate, escalate, and document. | “Exception generated” is not the same as “exception resolved.” |
| Heightened supervision | Used for higher-risk reps, products, branches, or patterns of complaints. | Heightened supervision must be tailored and documented, not merely punitive. |
| Books and records | Required records must be accurate, preserved, and retrievable. | Business texts, emails, chats, and social media can be firm records. |
| Business continuity | Firm must plan for emergency communications, data backup, customer access, and alternate operations. | BCP must be reasonably current and tested. |
OSJ, Branch, and Office Classification
| Classification issue | Key point |
|---|
| OSJ trigger | Common OSJ functions include final acceptance of new accounts, review/endorsement of orders, final approval of retail communications, market making/order execution, structuring offerings, or supervising other offices. |
| Branch office | Location where securities business is conducted, subject to registration and supervision unless an exclusion applies. |
| Non-branch location | Still requires supervision if firm business occurs there. “Not a branch” does not mean “not supervised.” |
| Remote work | Must fit WSPs, books-and-records capture, communications supervision, privacy safeguards, and customer protection controls. |
| Inspection priorities | Complaints, disciplinary history, outside activities, high production, complex products, penny stocks, senior clients, and remote supervision increase risk. |
| Item | Use | Principal-level exam point |
|---|
| Form U4 | Registers associated person and discloses required background information | Must be accurate and amended when reportable events occur. |
| Form U5 | Terminates registration and reports termination details | Must be truthful; vague or misleading termination language is a risk. |
| Form BD | Broker-dealer registration | Material business changes may require updates and supervisory review. |
| Form BR | Branch office registration | Office status and activities must match actual business. |
| Continuing education | Regulatory and firm training obligations | Training must address firm business, products, risks, and rule changes. |
| Statutory disqualification | Certain criminal, regulatory, or disciplinary events can restrict association | Firm cannot ignore disqualifying facts because the person is a high producer. |
| Permitted activities | Associated persons may only perform activities for which they are properly registered and supervised | Transaction-based compensation to an unregistered person is a classic trap. |
Principal Approval and Review Matrix
| Activity | Preapproval or review focus | Watch for |
|---|
| New account | CIP, KYC, account type, trusted contact request for retail customer, supervisory acceptance | Incomplete customer profile, suspicious identity, inappropriate account type |
| Margin account | Margin agreement, risk disclosure, suitability of margin strategy, hypothecation consent | Customer does not understand leverage or maintenance calls |
| Discretionary account | Written customer authorization and firm acceptance; prompt order review | Time/price discretion for same-day execution is not the same as full discretion |
| Options account | Options approval level, ODD delivery, customer financial profile, strategy suitability | Uncovered options for inexperienced or undercapitalized customer |
| Retail communication | Registered principal approval before use unless an exception applies; filing if required | Performance claims, guarantees, unbalanced risk disclosure |
| Correspondence | Supervision and review under WSPs; risk-based sampling may apply | Complaint hidden in email or text message |
| Institutional communication | Procedures, training, surveillance; principal approval not always required before use | Content still must be fair, balanced, and not misleading |
| Outside business activity | Prior written notice; firm evaluation and possible restrictions | Activity creates conflicts, uses firm customers, or resembles securities business |
| Private securities transaction | Prior written notice; if compensation, firm approval and supervision as firm business | Selling away through LLC, promissory notes, crypto-related private offering |
| Customer complaint | Capture, investigate, escalate, report if required, retain records | Oral grievance may become reportable if reduced to writing or tied to misconduct |
| Gift or entertainment | Track limits, business purpose, conflicts, recipient employer rules | “Entertainment” without host present can be treated as a gift |
| Borrowing/lending with customer | Only if firm permits and an exception applies | Customer consent alone does not make it permissible |
| Trade correction/cancel | Document reason, approval, customer impact, reporting correction | Pattern of corrections may indicate unauthorized trading or manipulation |
| Research publication | Analyst independence, conflict disclosures, information barriers | Investment banking influence over rating, target, or timing |
Customer Account and Recommendation Rules
KYC, Suitability, and Reg BI
| Standard | Applies when | Principal exam focus |
|---|
| FINRA KYC | Every account relationship | Know the customer: essential facts for servicing, authority, legal capacity, and compliance. |
| FINRA suitability | Recommendations not covered by Regulation Best Interest, including certain institutional contexts | Reasonable-basis, customer-specific, and quantitative suitability. |
| SEC Regulation Best Interest | Recommendation to a retail customer regarding securities transaction, strategy, or account type | Broker-dealer cannot place its interest ahead of retail customer’s interest. |
| Form CRS | Retail investor relationship summary | Delivery and consistency with actual services/conflicts. |
| Institutional suitability | Institutional customer can evaluate risks and independently exercise judgment | Not automatic; firm must have a reasonable basis for believing independence and capability. |
Regulation Best Interest Obligations
| Reg BI obligation | What it means in scenarios |
|---|
| Disclosure | Disclose capacity, material fees/costs, services, limitations, and conflicts. |
| Care | Understand risks, rewards, costs, and reasonably available alternatives; avoid excessive series of transactions. |
| Conflict of interest | Identify, disclose, mitigate, or eliminate conflicts as required. Sales contests based on specific securities over limited periods are high-risk. |
| Compliance | Maintain policies, procedures, training, and surveillance reasonably designed for Reg BI compliance. |
Account Type Decision Points
| Scenario | Correct supervisory concern |
|---|
| Retirement rollover recommendation | Treat as an account recommendation; compare costs, services, investment options, conflicts, and investor needs. |
| Senior investor adds new trusted contact | Trusted contact helps address suspected exploitation or diminished capacity; it does not give trading authority. |
| Customer grants POA to third party | Verify authority, monitor for abuse, and ensure records reflect authorized agent. |
| Customer wants aggressive trading in IRA | Customer desire does not override suitability/Reg BI care obligations. |
| Customer refuses financial information | Firm may limit recommendations or decline account features that require the information. |
| Customer gives verbal discretion | Not sufficient for discretionary account authority. Obtain required written authorization and approval. |
| Pattern day trading or active margin use | Confirm disclosures, margin suitability, equity requirements, and risk controls. |
AML, Privacy, and Red Flags
| Area | Principal must ensure | Exam red flags |
|---|
| AML program | Written program, designated AML officer, training, independent testing, suspicious activity escalation | Structuring deposits, rapid in-and-out wires, third-party checks, secrecy requests |
| CIP | Collect and verify required identity information before or within permitted account-opening procedures | Customer refuses ID, inconsistent address, shell entity with unclear ownership |
| Beneficial ownership | Identify and verify control/beneficial owners for legal entity customers as required | Entity layers, nominee owners, offshore secrecy jurisdictions |
| SAR process | Escalate suspicious activity; avoid tipping off customer | Rep tells customer a SAR may be filed |
| Sanctions/OFAC controls | Screen customers and transactions under firm procedures | Name match ignored because account is profitable |
| Privacy/Reg S-P | Safeguard nonpublic personal information; provide notices and opt-out where required | Sending account data to personal email or unauthorized vendor |
| Cybersecurity | Access controls, incident escalation, vendor oversight | Compromised rep email instructs wire transfer |
Communications Quick Reference
FINRA Communication Categories
| Category | Definition shortcut | Supervision point |
|---|
| Retail communication | More than 25 retail investors within a 30-calendar-day period | Generally requires registered principal approval before use, unless an exception applies. |
| Correspondence | 25 or fewer retail investors within a 30-calendar-day period | Supervised and reviewed under WSPs; risk-based review often tested. |
| Institutional communication | Only institutional investors | Procedures, training, and surveillance required; still subject to content standards. |
Content Standards
| Rule of thumb | Example of compliant approach | Problem answer |
|---|
| Fair and balanced | Benefits and risks appear together and with similar prominence. | Prominent yield claim with hidden risk footnote. |
| No exaggerated claims | “May provide income, subject to credit and market risk.” | “Safe income with no downside.” |
| No misleading performance | Include material assumptions, period, fees, and limitations. | Cherry-picked performance period. |
| No unwarranted projections | Use only permitted illustrations with required basis and disclosures. | Predicting stock price or fund return. |
| Comparisons must be valid | Compare similar products using disclosed assumptions. | Comparing taxable and tax-exempt yields without tax basis. |
| Testimonials/endorsements | Must meet applicable disclosure and compensation rules. | Paid influencer post without disclosure. |
Digital Communication Traps
| Situation | Exam treatment |
|---|
| Static webpage/profile describing services | Usually treated like retail communication; principal approval and records matter. |
| Interactive social media forum | Supervision, training, surveillance, and recordkeeping still apply. |
| Rep uses personal texting for business | Business communication must be captured, supervised, and retained if permitted at all. |
| Hyperlink to third-party content | Firm may adopt or become entangled with content depending on control and context. |
| Seminar invitation | Review both invitation and script/slides; audience and product claims matter. |
Sales Practice and Conduct Controls
| Issue | Rule logic | Common trap |
|---|
| Gifts | Business-related gifts are limited and must be tracked. | Splitting gifts through multiple reps or affiliates. |
| Business entertainment | Must be reasonable, not so frequent or expensive that it creates conflict. | Calling lavish travel “training.” |
| Non-cash compensation | Product-specific arrangements are restricted and must fit rule conditions. | Sales contest rewards pushing one fund, annuity, or REIT. |
| Borrowing/lending | Allowed only if firm permits and a rule exception applies. | Customer is “a friend” only because of brokerage relationship. |
| Sharing in customer account | Requires firm and customer written authorization; sharing generally must be proportionate to contributions. | Rep shares profits but not losses. |
| Guarantee against loss | Prohibited. | “I’ll make you whole if this drops.” |
| Churning/excessive trading | Quantitative suitability/Reg BI care issue; review turnover, cost-equity ratio, objectives. | Customer approved every trade but strategy is still excessive. |
| Unauthorized trading | Serious violation; prompt investigation and complaint handling. | Rep says customer “would have approved.” |
| Selling away | Private securities transaction outside firm approval/supervision. | Rep sells notes, private fund interests, or startup shares through personal email. |
| OBA | Prior written notice required; firm evaluates conflicts and customer confusion. | “It is not securities-related” does not end the analysis. |
Product Supervision Snapshot
| Product/activity | Supervisory focus | High-yield trap |
|---|
| Mutual funds | Share class, breakpoints, rights of accumulation, letters of intent, fund switching | Breakpoint sale: recommending purchases just below breakpoint or ignoring ROA/LOI. |
| Variable annuities | Long-term horizon, surrender charges, riders, tax deferral, exchange analysis, principal review | Replacing VA mainly for higher commission or unnecessary rider. |
| Direct participation programs / non-traded REITs | Due diligence, illiquidity, concentration, tax assumptions, distribution source | Treating distributions as guaranteed income. |
| Structured products | Issuer credit risk, payoff formula, caps, barriers, liquidity, complexity | “Principal protected” depends on issuer and terms. |
| Options | Approval level, ODD, strategy risk, uncovered exposure, exercise/assignment | Customer approved for covered calls trades naked options. |
| Penny stocks / low-priced securities | Disclosure, suitability, quote/compensation transparency, manipulation risk | Pump-and-dump red flags ignored. |
| Fixed income | Credit risk, interest-rate risk, duration, call risk, yield basis, markup/markdown | Reaching for yield without explaining call or credit risk. |
| ETFs and leveraged/inverse funds | Holding period, compounding, tracking error, volatility | Long-term holding of daily-reset leveraged ETF without analysis. |
| Private placements | Reasonable investigation, accredited/institutional status if relevant, conflicts, compensation | Relying solely on issuer-provided materials. |
| Complex products | Training, reasonable-basis suitability, customer-specific review, concentration limits | Product approved for sale but not suitable for customer. |
Investment Banking and New Issue Reference
Offering Types
| Offering type | Meaning | Principal focus |
|---|
| Firm commitment | Underwriter buys securities from issuer and resells | Underwriter assumes distribution risk; capital and due diligence matter. |
| Best efforts | Underwriter acts as agent to sell as much as possible | No guarantee issuer receives full proceeds. |
| All-or-none | Offering cancels unless all securities are sold | Customer funds must be handled consistently with contingency. |
| Mini-max | Minimum must be sold for offering to proceed; maximum caps size | Track escrow/release conditions and disclosures. |
| Standby underwriting | Underwriter agrees to purchase unsubscribed shares, often in rights offering | Analyze commitment, compensation, and capital impact. |
| Private placement | Exempt offering to qualified investors under exemption conditions | Due diligence and selling restrictions remain critical. |
Registered Offering Stages
| Stage | Permitted/forbidden concept | Exam trap |
|---|
| Pre-filing | Avoid gun-jumping; offers generally restricted before filing | Conditioning the market with promotional material. |
| Waiting/cooling-off | Indications of interest and preliminary prospectus activity may be allowed; no final sales before effectiveness | Taking customer money as if sale is final. |
| Effective/post-effective | Sales with required prospectus delivery and confirmations | Omitting final prospectus or material changes. |
IPO and New Issue Controls
| Topic | Key rule logic |
|---|
| Restricted persons | FINRA new issue rules restrict allocations to broker-dealer personnel and other restricted persons unless an exemption applies. |
| Account representations | Firm must obtain and maintain required eligibility representations for new issue accounts. |
| Spinning | Allocating IPO shares to executives/directors to win investment banking business is prohibited. |
| Quid pro quo allocations | Allocations tied to excessive compensation or future business are prohibited. |
| Flipping and penalty bids | Must be handled under syndicate rules and disclosed where required. |
| Laddering | Requiring aftermarket purchases as condition of IPO allocation is prohibited. |
| Underwriting compensation | Must be fair, reasonable, disclosed, and reviewed under applicable corporate financing rules. |
| Area | Principal-level takeaway | Scenario clue |
|---|
| Regulation M | Distribution participants may be restricted from bidding for or purchasing the offered security during a distribution. | Syndicate desk buys shares to support price without considering Reg M. |
| Stabilization | Can be permitted if conducted within strict conditions and disclosure rules. | Stabilization is not automatically illegal, but undocumented support is suspect. |
| Passive market making | May be allowed under conditions for certain Nasdaq distributions. | Market maker continues normal activity without checking distribution status. |
| Restricted list | Limits trading/recommendations when firm has MNPI or banking role. | Rep solicits stock while firm is advising issuer. |
| Watch list | Internal monitoring list, more confidential than restricted list. | Broadly sharing watch-list names can leak sensitive information. |
| Research analyst independence | Banking cannot dictate research content, rating, price target, or timing. | Banker asks analyst to promise favorable coverage. |
| Research disclosures | Conflicts, ownership, compensation, market making, and banking relationships may require disclosure. | Report omits firm’s underwriting role. |
| Information barriers | Separate MNPI from trading/sales/research through policies, access controls, and surveillance. | Wall crossing without controls or records. |
Trading, Market Making, and Order Handling
| Concept | Exam-ready rule |
|---|
| Best execution | Firm must use reasonable diligence to obtain the most favorable terms under the circumstances. Payment for order flow does not excuse poor execution. |
| Held order | Broker is expected to execute promptly and cannot use broad time/price discretion. |
| Not-held order | Customer grants discretion over time and price; still requires best execution and documentation. |
| Market order | Prioritizes execution, not price certainty. |
| Limit order | Sets price boundary; may miss execution. |
| Stop order | Becomes market order when triggered; execution price can differ from stop price. |
| Stop-limit order | Becomes limit order when triggered; execution is not guaranteed. |
| Customer limit order display | Market makers must display qualifying customer limit orders that improve price or add size unless an exception applies. |
| Manning/customer order protection | Firm generally cannot trade for its own account ahead of a customer order at a price that would satisfy the customer order. |
| Reg NMS trade-through | Protected quotations generally cannot be traded through unless an exception applies. |
| Firm quote | Published quotes create execution obligations subject to rules and exceptions. |
| Short sale locate | Locate must be obtained before effecting a short sale unless an exception applies. |
| Order marking | Orders must be marked long, short, or short exempt correctly. |
| Close-out | Fail-to-deliver positions require close-out under Reg SHO procedures. |
| Trade reporting | Equity, debt, and order lifecycle reports must be accurate, timely, and corrected when needed. |
Manipulation Red Flags
| Red flag | Why it matters |
|---|
| Wash trades or matched orders | Creates false appearance of activity. |
| Marking the close/open | Attempts to influence closing/opening price. |
| Layering/spoofing | Non-bona fide orders used to move market. |
| Parking stock | Hiding ownership or control. |
| Prearranged trades | May evade auction/market rules or create artificial prices. |
| Rumor spreading | Fraud/manipulation risk, especially around offerings or research. |
| Pump-and-dump pattern | Promotional activity followed by insider or customer liquidation. |
| Excessive cancellations | Can indicate spoofing or manipulative order entry. |
Trade Reporting, Confirmations, and Records
| Record/report | Principal focus |
|---|
| Order ticket/order record | Time, terms, account, capacity, solicited/unsolicited, long/short where relevant. |
| CAT reporting | Lifecycle order events must be captured accurately. |
| TRACE | Corporate and agency debt transaction reporting. |
| Equity trade reports | OTC/exchange reporting facility use must match trade type. |
| Customer confirmation | Capacity, price, remuneration, settlement, yield/other disclosures where required. |
| Account statement | Positions, balances, activity; review for errors and red flags. |
| Corrections/cancels | Must be supported, approved, and not used to hide errors or favor accounts. |
| Books and records retention | Preserve required records in accessible form; prevent alteration or unauthorized destruction. |
Financial Responsibility and Operations
| Rule area | What a Series 23 candidate should know |
|---|
| Net capital rule | Broker-dealers must maintain liquid net capital; business expansion, underwriting, proprietary trading, and market making can affect capital. |
| Haircuts | Securities positions are reduced in value for net capital purposes based on risk. |
| Aggregate indebtedness/alternative standard | Net capital computations may use different methods depending on firm model. Know concept, not just math. |
| Customer protection rule | Fully paid and excess margin securities must be protected; customer reserve requirements segregate customer funds. |
| Possession or control | Firm must safeguard customer securities and resolve deficits. |
| SIPC | Protects customers if broker-dealer fails, within limits; does not protect against market losses. |
| Segregation | Customer and firm assets must not be misused or commingled improperly. |
| FOCUS and financial reporting | Financial condition reporting must be accurate and timely. |
| Introducing vs clearing firm | Allocation of operational duties must be clear, but introducing firm still supervises its own customer-facing activity. |
| Carrying agreement | Defines responsibilities between introducing and clearing firms; does not eliminate supervisory duties. |
Use formulas to support supervisory judgment. The exam may test whether a principal recognizes an account problem, unfair charge, margin deficiency, or yield misrepresentation.
Margin Basics
\[
\text{Long account equity} = \text{long market value} - \text{debit balance}
\]\[
\text{Short account equity} = \text{credit balance} - \text{short market value}
\]\[
\text{Reg T initial requirement for a long stock purchase} = 50\% \times \text{purchase price}
\]
| Margin concept | Plain-English use |
|---|
| Debit balance | Amount customer borrowed in a long margin account. |
| Credit balance | Proceeds and required deposit in a short margin account. |
| LMV | Long market value of securities. |
| SMV | Short market value of securities sold short. |
| SMA | Special memorandum account; can create buying power but is not cash. |
| Restricted account | Equity below initial requirement but above maintenance. |
| Maintenance call | Equity has fallen below maintenance requirement. |
| House requirement | Firm may impose stricter requirements than minimum rules. |
Markup, Markdown, and Yield
\[
\text{Markup percentage} =
\frac{\text{customer price} - \text{prevailing market price}}
{\text{prevailing market price}}
\times 100
\]\[
\text{Markdown percentage} =
\frac{\text{prevailing market price} - \text{customer price}}
{\text{prevailing market price}}
\times 100
\]\[
\text{Current yield} =
\frac{\text{annual income}}
{\text{market price}}
\]
| Concept | Exam reminder |
|---|
| 5% policy | A guideline, not a safe harbor. Facts and circumstances control. |
| Prevailing market price | Reference point for markup/markdown analysis. |
| Riskless principal | Compensation disclosure and fair pricing still matter. |
| Current yield | Ignores maturity, call features, and reinvestment risk. |
| Yield to maturity | Incorporates price, coupon, and maturity. |
| Yield to call | Important when bond is callable and trading at a premium. |
Common Series 23 Scenario Traps
| Trap | Better exam answer |
|---|
| “The customer signed a risk disclosure, so the recommendation is fine.” | Disclosure helps but does not replace Reg BI, suitability, or supervision. |
| “Institutional account means no suitability duty.” | Institutional capability and independent judgment must be assessed. |
| “The branch is profitable, so inspect less.” | Profitability can increase risk; complaints and activity drive supervisory attention. |
| “A principal approved the ad after it was used.” | Retail communications generally require approval before use unless an exception applies. |
| “Rep only sold the private deal to friends.” | If securities-related, analyze private securities transaction and selling away rules. |
| “Customer allowed discretion verbally.” | Written authorization and firm acceptance are required for discretionary accounts. |
| “The firm’s quote was only an indication.” | Published firm quotes can create execution obligations. |
| “Best execution means lowest commission.” | It includes price, speed, likelihood, size, market quality, and overall execution quality. |
| “Reg BI requires recommending the cheapest product.” | Cost is important, but recommendation must consider full facts and alternatives. |
| “SIPC makes customer whole.” | SIPC does not insure against investment decline. |
| “Research can be delayed until banking approves.” | Banking influence over research content/timing is a conflict issue. |
| “Stabilization is always manipulation.” | Stabilization can be permitted if conducted under applicable conditions and disclosures. |
| “AML concern is only cash.” | Wires, journals, securities movements, third parties, and account behavior can trigger AML review. |
| “No customer complaint because it came by email.” | Written electronic grievances can be complaints and records. |
| “House rules are optional if FINRA minimum is met.” | Firm procedures and house requirements are enforceable supervisory standards. |
Final Cram Checklist
Before exam day, be able to answer these quickly:
- Who must approve or review the activity?
- Is approval required before use, before trade, or through post-use surveillance?
- Is the communication retail, correspondence, or institutional?
- Is the interaction a recommendation under Reg BI or FINRA suitability?
- What customer facts are missing?
- Is the customer retail, institutional, accredited, senior, or entity-based?
- Is the rep properly registered for the activity?
- Is the office correctly classified and inspected?
- Does the firm have WSPs that match the activity?
- Did an exception report require follow-up?
- Is there a conflict of interest, compensation conflict, or sales contest issue?
- Is there MNPI or an information-barrier concern?
- Does the trade raise best execution, limit order, Manning, or short sale concerns?
- Is a trade report, confirmation, or order record inaccurate?
- Does the offering involve restricted persons, spinning, Reg M, or underwriting compensation?
- Is a private placement being sold with adequate due diligence?
- Is a product complex, illiquid, leveraged, callable, or fee-heavy?
- Are customer assets protected and properly segregated?
- Does AML or sanctions review need escalation?
- Was the supervisor’s decision documented?
Practical Next Step
Use this Quick Reference as a checklist while working timed Series 23 practice questions. For every missed item, write the rule trigger, the supervisory action required, and the red flag you failed to recognize.