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Zorluk: KolayFinancial Exploitation of Senior Investors and Vulnerable Adults

A registered representative suspects that a 70-year-old customer is a victim of financial exploitation by a caregiver attempting to withdraw funds. Under FINRA Rule 2165, which of the following compliance actions is the member firm permitted to take?

  1. Place a temporary hold on the requested disbursement of cash or securities from the account.Cevap
  2. B
    Freeze all securities trading activity and refuse to execute any buy or sell orders placed by the customer.
  3. C
    Immediately terminate the customer account and liquidate all current holdings into cash.
  4. D
    Block all incoming deposit transfers while permitting unrestricted outgoing wire requests.

Cevap

Place a temporary hold on the requested disbursement of cash or securities from the account.
Placing a temporary hold on cash or securities disbursements is correct because FINRA Rule 2165 grants broker-dealers a safe harbor to temporarily pause outgoing fund or security transfers when there is reasonable suspicion of financial exploitation involving a specified adult (aged 65 or older).

Adım Adım Çözüm

1
Identify the applicable regulatory rule
FINRA Rule 2165 governs financial exploitation of specified adults (individuals aged 65 and older, or aged 18 and older with mental/physical impairments).
Understanding the rule's scope establishes what safeguards are authorized.
2
Determine authorized firm actions under Rule 2165
The rule permits placing a temporary hold specifically on disbursements of cash or securities from the customer's account.
Disbursement holds prevent unauthorized removal or transfer of assets.
3
Distinguish disbursement holds from trading restrictions
Rule 2165 does NOT authorize freezing trade execution or liquidating portfolios.
The hold applies strictly to outward disbursements, ensuring standard investment transactions may continue.

Anahtar Kavram

FINRA Rule 2165 Temporary Hold Scope
Tahmini Süre:50s
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Konular

Financial Exploitation of Senior Investors and Vulnerable Adults