Question

Difficulty: EasyFinancial Exploitation of Senior Investors and Vulnerable Adults

A broker-dealer places a temporary hold on a requested cash disbursement from a 72-year-old customer's account due to reasonable suspicion of financial exploitation. According to FINRA Rule 2165, which action is the firm required to take following the placement of this hold?

  1. Provide notification of the hold and the reason for it to all authorized account parties and the designated trusted contact person within two business days.Answer
  2. B
    Immediately freeze all securities trading activity and cancel all pending buy and sell orders in the account.
  3. C
    Obtain written approval from FINRA or state securities regulators prior to placing the initial temporary hold.
  4. D
    Automatically liquidate the customer's securities holdings to cash to prevent market losses during the review period.

Answer

Provide notification of the hold and the reason for it to all authorized account parties and the designated trusted contact person within two business days.
Under FINRA Rule 2165, placing a temporary hold on a disbursement requires the member firm to initiate an internal review and provide notification of the hold (along with the reason) to all parties authorized to transact business on the account and the designated trusted contact person no later than two business days after the hold was placed.

Step-by-Step Solution

1
Identify the governing regulation for financial exploitation holds.
FINRA Rule 2165 governs temporary disbursement holds for specified adults (individuals aged 65 or older, or aged 18 or older with mental/physical impairments).
Establishing the regulatory framework clarifies the procedural compliance requirements.
2
Determine the mandatory post-hold notification requirements.
Rule 2165 requires the member firm to initiate an internal review and notify all authorized account transactors and the designated trusted contact person within two business days of placing the hold.
Timely notice ensures that authorized individuals or trusted parties are aware of potential exploitation concerns while the firm investigates.

Key Concept

FINRA Rule 2165 Disbursement Hold Notification Timelines
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