At a minimum, the record must include all the identifying information gathered by the firm about a customer.
With regard to verification, a firm's records must contain a description of any document that was relied on to verify the customer's identity, noting the type of document, any identification number contained in the document, the place of issuance, and, if any, the date of issuance and expiration date.
In addition, transfers of accounts that result from an introducing broker/dealer changing its clearing firm would fall within this exclusion.
NASD rules clarify that the activities triggering registration include the functions of supervision, solicitation, or conduct of business in securities, or the training of persons associated with a member for any of these functions.
Thus, instructing registered persons on the use of suspicious activity reports would not alone trigger registration requirements, but instructing registered persons on particular securities products could trigger registration requirements.
FINRA Rule 3310.02 requires members to review and, if necessary, update their emergency contact information in the manner prescribed by NASD Rule 1160.
NASD Rule 1160 requires firms, via the FINRA Contact System, to update designated contact information promptly upon any material change (but no later than 30 days following the change) and verify such information within 17 business days after the end of each calendar year.
A broker-dealer must retain records of all of the identification information obtained from the customer for five years after the account is closed.
In addition, records made about information that verifies a customer's identity only have to be retained for five years after the record is made. The final rule defines an "account" as a formal relationship with a broker/dealer established to effect transactions in securities, including, but not limited to, the purchase or sale of securities, securities loaned and borrowed activity, and the holding of securities or other assets for safekeeping or as collateral.FINRA is collecting the contact information through the FINRA Contact System (FCS) available on the FINRA website. Have the customer identification requirements for opening a DVP account been established?Customer identification requirements in .220 apply to all customers opening a new account as those terms are defined in the Bank Secrecy Act and implementing regulations, including DVP accounts.Whether or not an AML compliance officer is registered with, or an employee of, the firm, an AML compliance officer is an associated person of the firm.(See FINRA Rule 3310; NASD Notice to Members 02-80, fn.5; NASD Notice to Members 06-07.) 5.Some firms use outside vendors to conduct non-documentary verification on DVP accounts.