CLM supports with a questionnaire – applicable to both entities and individuals – the following four aspects of the FINRA KYC and suitability rules:
- Institutional Customer Exemption
The exception from conducting customer-specific suitability assessment for institutional customers.
- Customer Investment Profile
The data to be collected for building the investment profile of the customer, which partially varies depending on the type of customer.
- Suitability assessments
It covers the three obligations that compose the suitability requirement: reasonable basis, customer-specific, and quantitative.
It covers the special handling instructions for the account.
The FINRA questionnaire does not cover the FINRA Rule 2090 KYC obligation to “understand the authority of each person acting on behalf of the customer” because this essential fact is collected within the CLM application via the ‘Add related parties’ step and the relevant AML questionnaire in the corresponding Related Party sub-case, plus the collection of the documents relevant for such person.