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Zorluk: ZorFinancial Exploitation of Senior Investors and Vulnerable Adults

Under FINRA Rule 2165, if a broker-dealer places a temporary hold on a disbursement of funds due to suspected financial exploitation of a senior investor, the firm is required to notify the customer's designated trusted contact person within two business days, even if the firm reasonably suspects that the trusted contact person is involved in the exploitation.

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False. Under FINRA Rule 2165, member firms must notify authorized account parties and the trusted contact person within two business days of placing a disbursement hold, unless the firm reasonably suspects the trusted contact person is involved in the financial exploitation.
The correct answer is False because FINRA Rule 2165 explicitly exempts member firms from notifying a designated trusted contact person if the firm reasonably believes that the trusted contact person is involved in the financial exploitation.

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1
Analyze FINRA Rule 2165 notification requirements for disbursement holds.
Member firms are required to notify all authorized account transactors and the designated trusted contact person no later than two business days after placing a temporary hold on disbursements.
Prompt notification ensures authorized individuals are aware of suspected exploitation and account restrictions.
2
Evaluate the regulatory exception regarding suspected perpetrators.
FINRA Rule 2165 contains a specific exemption stating that notification to the trusted contact person is NOT required if the firm reasonably believes that the trusted contact person is engaged in or attempting the financial exploitation.
Notifying a suspected perpetrator would compromise the account's security and ongoing internal investigation.
3
Determine the truth value of the stem statement.
The statement asserts that notification is mandatory even if the trusted contact is suspected of involvement, which contradicts FINRA Rule 2165.
Because the rule explicitly waives notification when the trusted contact is suspected of involvement, the statement is false.

Anahtar Kavram

FINRA Rule 2165 Trusted Contact Exception
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Financial Exploitation of Senior Investors and Vulnerable Adults