Exam identity and operating mindset
This independent Quick Reference supports preparation for FINRA’s Series 99 — Operations Professional Qualification Examination (Series 99). The exam is operations-focused: expect questions about how broker-dealer processing, records, controls, customer assets, and regulatory obligations work in practice.
High-yield Series 99 mindset
| If the question asks about… | Think first about… | Common trap |
|---|
| Customer money or securities | Authorization, possession/control, segregation, records | Treating customer assets as firm assets |
| Account opening or update | Identity, authority, tax status, suitability/KYC where applicable, approval | Processing before required documentation is complete |
| Trade processing | Accurate order data, comparison, clearing, settlement, confirmations | Confusing execution date with settlement date |
| Trade break, fail, or exception | Reconcile, investigate, correct, escalate, document | Ignoring a break because economics appear small |
| Margin or stock loan | Collateral, equity, debit/credit balances, rehypothecation limits | Confusing customer debit with customer credit |
| Regulatory inquiry | Preserve records, respond truthfully through firm channels | Altering, deleting, or informally “fixing” records |
| Suspicious activity | Escalate to AML/compliance; do not tip off | Trying to decide alone whether a SAR is required |
| Operations employee conduct | FINRA ethical standards, supervision, confidentiality | Assuming conduct rules only apply to registered reps |
Core market and operations infrastructure
| Entity or system | Operations role | Exam-relevant distinction |
|---|
| FINRA | Regulates broker-dealers and associated persons | Exam vendor/provider for Series 99; not a clearing agency |
| SEC | Federal securities regulator | SEC rules often govern customer protection, books and records, net capital |
| MSRB | Municipal securities rulemaking body | Rules municipal securities dealers; enforcement handled by other regulators |
| Federal Reserve Board | Regulates credit extension under Regulation T | Initial margin requirement source for many securities transactions |
| DTCC | Holding company for market infrastructure | Includes DTC and NSCC |
| DTC | Depository for securities custody and book-entry movement | Securities position movement, not trade execution |
| NSCC | Clears and nets many broker-dealer securities trades | CNS netting, comparison, settlement obligations |
| OCC | Clearing corporation for listed options | Exercise, assignment, and options contract guarantee |
| Transfer agent | Maintains issuer securityholder records | Re-registration, lost certificates, corporate actions |
| Clearing firm / carrying firm | Holds customer accounts, clears and settles trades | Responsible for custody, statements, confirmations if carrying |
| Introducing firm | Introduces customers to carrying firm | May handle sales/customer relationship but not custody if fully disclosed |
| Prime broker | Provides custody, financing, settlement coordination for institutional clients | Executing broker and prime broker roles differ |
| Custodian | Holds assets for customer or institution | Custody is not the same as investment discretion |
| Issuer | Entity whose securities are traded | Corporate action source, not necessarily the paying agent |
| Paying agent | Distributes interest, dividends, principal, or redemption proceeds | Operational cash flow processor |
Account lifecycle reference
Account opening and onboarding controls
| Requirement area | What operations verifies | Watch for |
|---|
| Customer identity | Name, address, date of birth for individuals, tax ID or equivalent; entity documentation for non-individuals | Incomplete CIP information, mismatched identifiers |
| Authority | Who may open, trade, transfer, or withdraw | POA, corporate resolution, trust document, partnership agreement |
| Tax status | W-9, W-8 series, backup withholding status, exempt status where applicable | Missing TIN, foreign indicia, expired documentation |
| Customer profile | Investment objective, risk tolerance, financial situation as required by firm procedures | Operations may capture data even if not making recommendations |
| Account type | Cash, margin, options, retirement, advisory, fiduciary, entity | Applying margin or options features without approval |
| Disclosures and agreements | Margin agreement, options agreement, customer agreement, privacy notices | Features cannot be used before approval/acceptance |
| Funding source | Check, ACH, wire, ACATS, journal, transfer | Third-party wires, suspicious source of funds |
| Restrictions | Legal holds, control/restricted stock, sanctions, deceased owner, court order | Processing disbursement despite restriction |
| Beneficiaries | TOD, retirement beneficiary, trust beneficiaries if applicable | Beneficiary designation does not override all legal restrictions |
| Trusted contact | Contact person for suspected exploitation or inability to contact customer | Trusted contact is not trading authority |
Common account types
| Account type | Key operations point | Exam trap |
|---|
| Individual | One legal owner | Do not accept instructions from spouse/family without authority |
| Joint tenants with rights of survivorship | Surviving owner generally receives decedent’s interest | Verify death documentation and firm procedure |
| Tenants in common | Decedent’s interest passes through estate | Do not assume survivorship |
| Community property | State-law ownership rules may apply | Do not treat like standard JTWROS automatically |
| UTMA/UGMA custodial | Custodian acts for minor | Minor does not trade; transfers at age of majority per state law |
| Trust | Trustee acts under trust powers | Need trustee authority; beneficiaries usually do not direct trades |
| Estate | Executor/personal representative acts | Require appointment documentation |
| Corporation | Authorized officers act under corporate authority | Verify resolutions/incumbency |
| Partnership/LLC | Authorized partners/managers act | Authority comes from agreement/resolution |
| IRA | Tax-advantaged retirement account with custodian/trustee | Margin, options, and distributions have special limits |
| ERISA/qualified plan | Plan fiduciaries act | Fiduciary capacity and prohibited transaction concerns |
| Omnibus account | One account holds positions for underlying customers | Broker-dealer must know operational responsibilities and recordkeeping role |
Trade lifecycle
flowchart LR
A[Order entered] --> B[Execution]
B --> C[Trade capture]
C --> D[Comparison / matching]
D --> E[Clearing and netting]
E --> F[Settlement]
F --> G[Books, records, statements]
D --> H[Trade break or DK]
H --> I[Research, correct, approve, document]
I --> D
| Stage | Operations focus | Common exception |
|---|
| Order entry | Correct account, security, side, quantity, price terms, capacity | Wrong account, wrong symbol/CUSIP, unauthorized order |
| Execution | Trade details captured from market/executing venue | Late trade reporting, price discrepancy |
| Comparison/matching | Contra-party confirms economic details | DK, unmatched institutional allocation |
| Clearance | Obligations netted and prepared for settlement | Fail to receive/deliver, CNS exception |
| Settlement | Securities delivered vs. funds paid | Customer lacks shares or cash |
| Post-settlement | Confirmations, statements, cost basis, reconciliation | Books and records break |
| Correction | Cancel/rebill, as-of trade, journal, price correction | Correcting without approval trail |
Settlement and date conventions
Regular-way settlement reference
| Product or transaction | Common settlement convention | Operations notes |
|---|
| Listed equities and ETFs | Generally T+1 | Settlement date drives cash due, delivery, fails, and ex-dividend mechanics |
| Corporate bonds | Generally T+1 | Invoice includes accrued interest unless trading flat |
| Municipal securities | Generally T+1 | Accrued interest and MSRB reporting concepts are testable |
| U.S. government securities | Commonly T+1 | Some transactions may use cash or special settlement by agreement |
| Listed options | Generally T+1 | OCC handles clearance, exercise, and assignment |
| Mutual funds | As specified by fund; many settle T+1 | Priced at forward NAV after order receipt |
| New issues | Per offering terms | Do not assume secondary-market settlement |
| Cash trade | Same-day settlement | Requires same-day funds/securities readiness |
| When-issued trade | Settles when issued and available | Used before final issuance/delivery details are complete |
Dividend and corporate action dates
| Date | Meaning | Exam point |
|---|
| Declaration date | Board announces dividend | Creates expected payment terms |
| Ex-dividend date | First day buyer is not entitled to regular dividend | Buy before ex-date to receive; buy on/after ex-date generally does not |
| Record date | Issuer determines holders of record | Settlement timing determines ownership of record |
| Payable date | Dividend paid | Cash or securities credited through operations systems |
| Due bill period | Entitlement tracking when settlement/record timing creates mismatch | Prevents dividend going to wrong economic owner |
Settlement vocabulary
| Term | Meaning | Operations response |
|---|
| Fail to deliver | Seller did not deliver securities by settlement | Monitor, resolve, possible buy-in/close-out rules |
| Fail to receive | Buyer did not receive securities | Reconcile contra-party obligation |
| DK / don’t know | Contra-party does not recognize trade details | Research trade data and resolve promptly |
| Buy-in | Buyer obtains securities because seller failed to deliver | Follow notice, timing, and firm procedures |
| Sell-out | Firm sells securities because customer did not pay | Requires appropriate notice/procedure |
| Reclamation | Return/reversal of previously delivered securities | Often due to defective delivery or documentation issue |
| As-of trade | Trade entered after actual trade date | Must preserve true economic trade date |
| Cancel/rebill | Corrects trade details by canceling and rebooking | Requires approval and audit trail |
| Trade break | System or ledger mismatch | Investigate root cause, not just dollar amount |
| Step-out | Allocation of executed trade to another broker/dealer | Institutional processing issue |
| Allocation | Assigning block trade quantities to accounts | Must match instructions and timing controls |
Product operations matrix
| Product | Processing focus | High-yield traps |
|---|
| Common stock | Book-entry custody, dividends, splits, voting, transfer | Long position ownership differs from trade-date execution until settlement |
| Preferred stock | Dividends, calls, conversions, ratings | Equity security with bond-like features |
| ETFs | Equity-like trading, creation/redemption by authorized participants | Intraday market price can differ from NAV |
| Corporate bonds | Accrued interest, calls, maturities, ratings, TRACE reporting concepts | Quote price excludes accrued interest unless stated |
| Municipal bonds | Accrued interest, MSRB rules, call features, tax status | Do not apply corporate bond rules blindly |
| Treasuries | Government security settlement, accrued interest, maturities | T-bills trade at discount, not coupon interest |
| Agency securities | Issuer/guarantor distinctions | Agency does not always mean full U.S. government guarantee |
| Mortgage-backed securities | Pool factors, principal paydowns, prepayment risk | Face amount declines with principal payments |
| Listed options | OCC clearance, exercise/assignment, expiration, approval level | Option premium settlement differs from stock ownership |
| Mutual funds | Forward pricing, NAV, breakpoints, exchanges, redemptions | No intraday execution at a chosen market price |
| UITs | Fixed portfolio, units, termination date | Not actively managed like open-end fund |
| ADRs | Depositary receipts for foreign shares | Currency, foreign tax, depositary fees |
| Restricted/control securities | Transfer restrictions, Rule 144 concepts, legal opinions | Cannot process as freely tradable without clearance |
| Money market funds | Liquidity, NAV, sweep processing | Not the same as bank deposits |
| Annuities/insurance-linked products | Carrier processing, suitability documentation, surrender terms | Broker-dealer records may interact with insurance carrier records |
Core margin account equations
\[
\text{Long Equity} = \text{Long Market Value} - \text{Debit Balance}
\]\[
\text{Short Equity} = \text{Credit Balance} - \text{Short Market Value}
\]\[
\text{Equity Percentage} = \frac{\text{Equity}}{\text{Market Value}}
\]
| Concept | Meaning | Exam distinction |
|---|
| Debit balance | Amount customer owes broker-dealer in long margin account | A customer liability to the firm |
| Credit balance | Funds held in short account, including short sale proceeds and margin deposit | Not all freely withdrawable |
| Long market value | Current value of long securities | If LMV falls, equity falls |
| Short market value | Current value of securities sold short | If SMV rises, equity falls |
| Regulation T | Federal Reserve initial margin framework | Initial margin is different from maintenance margin |
| Maintenance margin | Ongoing minimum equity requirement | Can be stricter under firm house rules |
| SMA | Special Memorandum Account tracking excess equity in margin accounts | Not cash; represents borrowing capacity |
| Margin call | Demand for additional equity/collateral | Failure can result in liquidation |
| Day trading controls | Special equity and buying-power rules may apply | Do not confuse ordinary margin with pattern day trading |
Margin quick examples
| Scenario | Effect |
|---|
| Customer buys stock in margin account | Debit balance increases; customer must meet initial margin |
| Long stock price rises | Equity rises; SMA may increase |
| Long stock price falls | Equity falls; maintenance call may occur |
| Customer sells stock short | Credit balance is created; short market value liability exists |
| Short stock price rises | Short equity decreases; risk increases |
| Customer deposits cash | Debit decreases or credit increases; equity improves |
| Customer withdraws cash | Equity decreases; may be restricted by margin rules |
Customer protection and financial responsibility
Customer Protection Rule concepts
\[
\text{Simplified Reserve Need} = \max(\text{Customer Credits} - \text{Customer Debits}, 0)
\]
This is a conceptual memory aid, not the full regulatory computation.
| Concept | Operations meaning | Exam focus |
|---|
| Fully paid securities | Customer securities with no customer debit against them | Must be protected from improper firm use |
| Excess margin securities | Margin securities above permitted rehypothecation amount | Customer protection issue |
| Possession or control | Firm must hold customer securities in acceptable locations or control arrangements | Prevents misuse or loss of customer assets |
| Reserve account | Special bank account for exclusive benefit of customers | Protects customer cash credits |
| Free credit balance | Cash owed by broker-dealer to customer | Must be properly recorded and protected |
| Customer debit | Amount customer owes broker-dealer | Reduces reserve formula credits conceptually |
| Segregation | Separation of customer property from firm property | Do not commingle |
| Rehypothecation | Firm use of customer margin securities as collateral within limits | Not permitted for fully paid securities |
| Stock loan/borrow | Borrowing/lending securities with collateral | Requires collateral tracking, marks, and recalls |
| Net capital | Broker-dealer liquidity standard | Protects firm solvency and orderly liquidation |
Net capital concept
\[
\text{Net Capital} \approx \text{Liquid Net Worth} - \text{Nonallowable Assets} - \text{Haircuts} - \text{Operational Charges}
\]
| Term | Meaning |
|---|
| Nonallowable asset | Asset not readily convertible to cash or not recognized for net capital |
| Haircut | Deduction for market, credit, or liquidity risk |
| Aggregate indebtedness | Certain unsecured liabilities used in financial responsibility calculations |
| Early warning level | Threshold requiring heightened regulatory attention |
| FOCUS report | Broker-dealer financial and operational filing |
Books, records, and reconciliations
| Record/control area | What must be accurate | Why it matters |
|---|
| Blotters | Daily securities and cash activity | Reconstructs activity and supervision |
| General ledger | Firm financial books | Supports net capital and reserve computations |
| Stock record | Customer and firm securities positions | Identifies possession/control and breaks |
| Customer account record | Registration, tax, address, investment profile, authorities | Prevents unauthorized processing |
| Confirmations | Trade economics, capacity, price, fees/charges where applicable | Customer notice and regulatory record |
| Statements | Positions, cash balances, activity | Customer reconciliation and error detection |
| Order tickets | Order terms and timestamps | Audit trail for execution and corrections |
| Exception reports | Breaks, fails, margin deficits, restricted accounts | Supervisory escalation |
| Electronic communications | Business communications and approvals | Must be retained and supervised under firm policy |
| Audit trail | Who did what, when, and why | Critical for corrections and regulatory inquiries |
Reconciliation priorities
- Compare internal ledgers to clearing/depository/custodian records.
- Identify breaks by security, quantity, account, cash amount, and date.
- Determine whether the break affects customer assets, settlement, or regulatory computations.
- Correct through approved workflows only.
- Document root cause, approval, and final resolution.
- Escalate repeat breaks or control failures.
Regulatory and rule-area map
| Rule area | Core Series 99 concept | Practical exam cue |
|---|
| SEC books and records rules | Broker-dealers must create and preserve required records | Missing record is a regulatory issue even if no customer loss |
| SEC Customer Protection Rule | Protect customer cash and securities | Fully paid securities cannot be treated as firm collateral |
| SEC Net Capital Rule | Maintain liquid capital after deductions | Illiquid assets and market risk reduce usable capital |
| Regulation T | Federal margin credit regulation | Initial margin vs maintenance margin |
| FINRA supervision rules | Procedures, review, escalation, supervisory approval | Operations employees act within firm WSPs |
| FINRA account record rules | Accurate customer account information | Update material changes and authority |
| FINRA margin rules | Maintenance and operational margin controls | House requirements can be stricter |
| FINRA trade reporting concepts | Accurate and timely trade data | Reporting is not the same as clearing |
| FINRA communications/ethics rules | Fair dealing, no false records, no misuse of assets | Applies to associated persons |
| MSRB rules | Municipal securities processing and conduct | Municipal trades have specialized rule framework |
| Regulation SHO | Locate, short sale marking, close-out concepts | Long sale vs short sale marking matters |
| Regulation M | Distribution-related trading restrictions | Prevents manipulative activity around offerings |
| Regulation S-P | Customer privacy and safeguarding information | Protect nonpublic personal information |
| Regulation S-ID | Identity theft red flags program | Account takeover and suspicious address changes |
| AML/CIP | Identify customers and escalate suspicious activity | Do not tip off customers |
| OFAC/sanctions screening | Screen against sanctions restrictions | Escalate potential matches; do not process blindly |
| Business continuity | Continue critical operations during disruption | Backup systems, communications, and recovery |
Trade reporting, confirmations, and capacity
| Concept | Meaning | Trap |
|---|
| Agent capacity | Broker-dealer acts for customer and charges commission | Firm does not take proprietary position as counterparty |
| Principal capacity | Broker-dealer buys/sells from its own inventory | Markup/markdown instead of commission |
| Riskless principal | Firm fills customer order after offsetting trade | Must be reported/confirmed correctly |
| Confirmation | Customer disclosure of executed trade details | Not the same as monthly statement |
| Trade report | Regulatory/market report of trade data | Not the same as customer confirmation |
| TRACE | Corporate and agency debt trade reporting system | Debt reporting, not equity tape |
| RTRS | Municipal trade reporting system | MSRB municipal reporting |
| CAT | Consolidated Audit Trail for order/trade lifecycle | Order-event audit trail concept |
| Capacity code | Indicates agent/principal role | Wrong capacity affects disclosure and reporting |
| Contra party | Other side of trade/settlement | Matching issue source |
Corporate actions and reorganization processing
| Corporate action | Mandatory or voluntary | Operations focus |
|---|
| Cash dividend | Mandatory once declared | Entitlement, record date, payable date, tax reporting |
| Stock dividend | Mandatory | Adjust shares and cost basis/price references |
| Forward split | Mandatory | More shares, lower per-share price proportionally |
| Reverse split | Mandatory | Fewer shares, higher per-share price proportionally; handle fractional shares |
| Name/CUSIP change | Mandatory | Update security master and position records |
| Merger | Usually mandatory once approved | Exchange ratio, cash-in-lieu, tax reporting |
| Spin-off | Mandatory | Allocate cost basis and new security positions |
| Rights offering | Voluntary | Customer election, expiration, oversubscription if available |
| Tender offer | Voluntary | Customer election, proration, withdrawal rights if applicable |
| Exchange offer | Voluntary | Election between securities/cash terms |
| Call/redemption | Mandatory if called | Calculate redemption proceeds and accrued interest |
| Proxy vote | Voluntary customer action | Record date ownership and voting authority |
| Bankruptcy/reorg | Event-driven | Restrictions, new securities, write-downs, claims process |
Split adjustment memory aid
| Event | Shares | Price per share | Total market value before market movement |
|---|
| 2-for-1 split | Doubles | Halves | Same |
| 1-for-2 reverse split | Halves | Doubles | Same |
| 3-for-2 split | Multiplied by 1.5 | Divided by 1.5 | Same |
Bond processing and accrued interest
\[
\text{Accrued Interest} = \text{Par Value} \times \text{Coupon Rate} \times \frac{\text{Days Accrued}}{\text{Day-Count Basis}}
\]\[
\text{Bond Invoice Amount} = \text{Dollar Price} + \text{Accrued Interest}
\]
| Bond type | Day-count convention commonly tested | Note |
|---|
| Corporate bonds | 30/360 | Each month treated as 30 days; year as 360 |
| Municipal bonds | 30/360 | Similar accrued-interest convention to corporates |
| U.S. Treasury notes/bonds | Actual/actual | Count actual days in period/year |
| Treasury bills | Discount basis | No coupon accrued interest |
| Term | Meaning |
|---|
| Par | Face value used for interest/principal calculations |
| Coupon | Stated annual interest rate |
| Current yield | Annual interest divided by market price |
| Yield to maturity | Yield if held to maturity considering price and coupon |
| Yield to call | Yield assuming bond is called on call date |
| Premium bond | Price above par |
| Discount bond | Price below par |
| Flat trading | Trades without accrued interest |
| Callable | Issuer may redeem before maturity |
| Sinking fund | Issuer retires debt over time |
Options operations essentials
| Area | Operations point | Trap |
|---|
| Approval | Options trading requires account approval by level/strategy | Do not process unapproved strategies |
| Premium | Buyer pays, seller receives | Premium is not margin equity by itself for all purposes |
| Exercise | Holder invokes right | OCC processing and deadlines matter |
| Assignment | Writer is selected to fulfill obligation | Customer may be assigned even if not expecting it |
| Expiration | Contract ceases after expiration | Exercise instructions must meet firm/OCC timing |
| American-style option | Exercisable before expiration | Most listed equity options are American-style |
| European-style option | Exercisable only at expiration | Common for some index options |
| Physical settlement | Underlying security delivered | Stock position/cash movement follows |
| Cash settlement | Cash amount exchanged | Common for many index options |
| Covered call | Short call backed by long underlying | Still has assignment risk |
| Cash-secured put | Short put backed by cash | Assignment creates purchase obligation |
| Spread | Long and short options combined | Margin and approval depend on risk structure |
Tax, cost basis, and withholding operations
| Item | Operations relevance | Exam trap |
|---|
| W-9 | U.S. person taxpayer certification | Missing/incorrect TIN can trigger backup withholding |
| W-8 series | Foreign status certification | Expiration and treaty claims require documentation controls |
| 1099-B | Proceeds and cost basis reporting for sales | Trade date and settlement date can affect tax year treatment |
| 1099-DIV | Dividend and distribution reporting | Qualified vs nonqualified handling depends on data |
| 1099-INT | Interest reporting | Bond interest and OID may require tracking |
| Covered security | Broker must report cost basis to IRS/customer | Not all legacy positions are covered |
| FIFO | Default cost basis method if no valid specific ID | Customer must identify lots timely under firm procedure |
| Specific identification | Customer chooses tax lots | Must be documented before/at disposition per procedure |
| Wash sale | Loss disallowed if substantially identical security acquired within applicable window | Basis adjustment, not merely ignored |
| Backup withholding | Withholding due to missing/invalid certification or IRS notice | Do not release around required withholding |
| Nonresident withholding | Applies to certain U.S.-source income paid to foreign persons | Depends on documentation and income type |
| Retirement distribution coding | Tax reporting depends on distribution type | Operations must code accurately; not tax advice |
Account transfers, withdrawals, and asset movement
| Process | Key controls | Common exception |
|---|
| ACATS transfer | Match customer registration, account type, TIN, delivering/receiving firm data | Rejection due to title mismatch or nontransferable asset |
| Partial transfer | Identify specific assets/cash to move | Residual sweeps and dividends after transfer |
| Full transfer | Move transferable assets and close account if appropriate | Illiquid, proprietary, or restricted assets remain |
| DTC transfer | Book-entry movement between participants | Wrong CUSIP or quantity |
| DWAC/DRS | Transfer-agent-based electronic movement | Requires issuer/transfer agent eligibility |
| Journal between accounts | Internal movement | Must have same beneficial owner or valid authorization |
| Wire | Cash movement through bank rails | Third-party wire, new instructions, account takeover risk |
| ACH | Electronic bank transfer | Name mismatch, return risk |
| Check disbursement | Physical or electronic payment | Address change plus disbursement request is red flag |
| IRA transfer/rollover | Retirement asset movement | Coding and tax reporting differ |
| Deceased account transfer | Estate/beneficiary processing | Freeze restrictions until documents reviewed |
Asset movement red flags
- New address, phone, email, or bank instructions followed by urgent withdrawal.
- Third-party disbursement without clear purpose or authorization.
- Customer appears coached, confused, or subject to exploitation.
- Repeated wires just below internal review thresholds.
- Funds from or to high-risk jurisdictions without clear rationale.
- Transfer request inconsistent with customer profile.
- POA requests that benefit the agent personally.
- Account takeover indicators: device change, failed logins, unusual IP, changed MFA.
AML, fraud, and escalation
| Red flag | Appropriate operations response |
|---|
| Incomplete or inconsistent identity documents | Do not complete onboarding until resolved under CIP procedures |
| Customer refuses required information | Escalate to AML/compliance |
| Rapid in-and-out movement of funds | Investigate and escalate |
| Trading with no economic purpose | Escalate suspicious pattern |
| Microcap deposit followed by immediate liquidation | Review for restricted stock, fraud, manipulation |
| Structuring to avoid reporting/review | Escalate; do not advise how to avoid controls |
| Sanctions screening potential match | Pause and escalate under firm procedure |
| Elder exploitation concern | Escalate to designated supervisory/compliance contacts |
| Employee asks to bypass controls | Refuse and escalate |
| Customer asks whether a suspicious activity report will be filed | Do not tip off; refer to policy/compliance |
Professional conduct quick table
| Conduct issue | Correct principle |
|---|
| Conversion or misuse of funds | Never use customer or firm assets improperly |
| False books and records | Records must be accurate, complete, and unaltered |
| Unauthorized trading | Customer authorization required; discretion requires written authority and firm approval |
| Sharing in customer account | Restricted and requires approval if allowed |
| Borrowing from/lending to customer | Generally restricted; follow firm and FINRA rules |
| Gifts and gratuities | Subject to firm policy and regulatory limits |
| Outside business activity | Must be disclosed and approved as required |
| Private securities transaction | Requires prior notice/approval where applicable |
| Confidential information | Protect customer and firm nonpublic information |
| Regulatory request | Respond truthfully through approved firm channels |
| Error handling | Report promptly; do not conceal or self-correct outside procedure |
| Personal trading | Follow firm employee account, preclearance, and restricted-list policies |
High-yield “choose the next action” guide
| Scenario | Best next action |
|---|
| Customer requests wire after same-day email and address change | Hold/review per policy; verify independently; escalate if suspicious |
| Trade settles but securities not delivered | Treat as fail; reconcile and follow fail/buy-in procedures |
| Customer disputes trade confirmation | Research order ticket, authorization, execution, and correction history |
| Operations employee notices ledger break affecting customer reserve | Escalate immediately; document and correct under supervision |
| New entity account lacks proof of authorized signer | Do not process transactions requiring authority |
| Customer wants to sell restricted stock | Review restriction, legend, Rule 144/legal opinion process |
| Elderly customer suddenly liquidates and wires to new third party | Escalate for possible exploitation and AML review |
| Contra-party DKs institutional trade | Compare economics, allocation, account, security identifiers; resolve break |
| Customer lacks cash on settlement date in cash account | Follow payment/default procedures; possible sell-out |
| Margin equity falls below requirement | Issue call or liquidate per firm procedure |
| Employee receives subpoena or regulator letter directly | Notify legal/compliance; preserve records |
| Firm system outage prevents normal processing | Activate business continuity and manual control procedures |
| Customer asks for tax advice on cost basis | Provide records/forms; refer to tax adviser |
| Customer wants to trade options in cash account without approval | Do not process until approval and documentation are complete |
Acronyms and terms to know
| Term | Stands for / meaning |
|---|
| ACATS | Automated Customer Account Transfer Service |
| AML | Anti-money laundering |
| BD | Broker-dealer |
| BCP | Business continuity plan |
| CAT | Consolidated Audit Trail |
| CIP | Customer Identification Program |
| CNS | Continuous Net Settlement |
| CUSIP | Security identifier for many U.S./Canadian securities |
| DRS | Direct Registration System |
| DTC | Depository Trust Company |
| DTCC | Depository Trust & Clearing Corporation |
| DWAC | Deposit/Withdrawal at Custodian |
| FOCUS | Financial and Operational Combined Uniform Single report |
| KYC | Know your customer |
| LMV | Long market value |
| NAV | Net asset value |
| NSCC | National Securities Clearing Corporation |
| OCC | Options Clearing Corporation |
| OFAC | Office of Foreign Assets Control |
| POA | Power of attorney |
| Reg SHO | Short sale regulation framework |
| Reg S-P | Privacy and safeguarding rule framework |
| Reg T | Federal Reserve margin credit regulation |
| RTRS | Real-Time Transaction Reporting System for municipal securities |
| SAR | Suspicious Activity Report |
| SIPC | Securities Investor Protection Corporation |
| SMA | Special Memorandum Account |
| SMV | Short market value |
| TRACE | Trade Reporting and Compliance Engine |
| WSPs | Written supervisory procedures |
Common Series 99 traps
- Execution date is not settlement date. Many cash, margin, dividend, and fail questions turn on settlement.
- Operations does not “advise around” controls. The correct answer is often verify, restrict, escalate, or document.
- Customer protection is about ownership and control, not just account balance.
- A trade correction must preserve the audit trail. Do not erase the original event.
- Firm house rules can be stricter than regulatory minimums.
- A trusted contact is not a power of attorney.
- A beneficiary is not automatically authorized to trade during the owner’s life.
- SIPC is not market-loss insurance. It addresses missing customer assets if a member firm fails, subject to its framework.
- Margin SMA is not cash. It represents excess equity/borrowing capacity.
- Short sale proceeds are not freely withdrawable customer cash.
- Tax reporting is not tax advice. Operations supplies accurate records and forms.
- A suspicious activity concern is escalated confidentially. Do not tip off the customer.
- Restricted securities require clearance before sale or transfer.
- Voluntary corporate actions require customer election; mandatory actions generally do not.
Final review checklist
Before practice questions, make sure you can quickly answer:
- Who holds the account: introducing firm, carrying firm, custodian, transfer agent, or depository?
- What documentation proves authority to act?
- Is the transaction trade-date, settlement-date, record-date, or payable-date driven?
- Is the asset fully paid, margin, pledged, restricted, borrowed, or loaned?
- Does the item affect customer reserve, net capital, possession/control, or books and records?
- Is the correct response processing, rejection, correction, disclosure, escalation, or supervisory approval?
- What record proves the action was authorized and completed correctly?
Next step: use this Quick Reference as a drill sheet, then work timed Series 99 practice questions focused on settlement exceptions, account authority, margin balances, customer protection, AML red flags, and operations controls.