Circumstances for Refusing, Restricting, or Closing Accounts
Chapters in this video
- 0:00 Four mandatory refusal triggers: CIP, AML, OFAC, unsuitability
- 1:37 CIP refusal versus illegal discrimination
- 2:11 OFAC specially designated nationals: the dual mandate trap
- 2:57 Suspicious Activity Report $5,000 threshold and tipping off
- 5:01 Pattern day trading versus free-riding penalties
- 6:08 Margin deficiency liquidation without notice
- 7:08 ACATS transfer timelines and valid exceptions
- 8:02 Rapid-fire exam recap
What this video covers
- The four mandatory refusal triggers: missing Customer Identification Program (CIP) information, suspicious activity under anti-money laundering (AML) rules, Office of Foreign Assets Control (OFAC) specially designated nationals (SDN) list matches, and unacknowledged unsuitable activity
- Why a CIP refusal is regulatory compliance, not illegal discrimination based on protected characteristics
- The dual mandate for OFAC SDN matches: block the account immediately AND report to OFAC, never just one or the other
- The $5,000 threshold for filing a Suspicious Activity Report (SAR) with the Financial Crimes Enforcement Network (FinCEN), and the absolute prohibition on tipping off the customer
- Pattern day trading requirements: four or more day trades in five business days, the $25,000 minimum equity rule, and the separate 90-day cash-available restriction for unmet special maintenance margin calls
- Free-riding in cash accounts: the 90-day freeze when buying and selling before paying, and why the account is restricted not closed
- Account closure for legitimate business reasons with reasonable notice, and the Automated Customer Account Transfer Service (ACATS) timeline: one business day to validate or take exception, then three business days to complete
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