FINRA Series 7 — All Questions

A listed company's board approves a material definitive agreement on Monday. By when must the company generally file a Form 8-K reporting it?

• a.The fifth calendar day after the event
• b.The tenth business day after the event
• c.The fourth business day after the event✓
• d.The end of the current quarter

Most Form 8-K triggering events must be reported within four business days. Calendar-day counting, waiting for quarter-end, and a ten-business-day window do not match the form's deadline.Exchange Act Form 8-K

A person becomes a director of a company with a class of registered equity securities. Within how many days must the director file an initial Form 3?

• a.2 business days after becoming an insider
• b.5 business days after the first trade
• c.30 days after the next annual meeting
• d.10 days after becoming an insider✓

The initial statement of beneficial ownership, Form 3, is due within 10 days after a person becomes an officer, director, or 10% holder. The two-business-day deadline belongs to Form 4 for later changes in ownership. The other timelines are not rules.Exchange Act Section 16(a)

An officer sells 2,000 shares of her company's stock on Monday. By when must she report the transaction on Form 4?

• a.On Form 5 with the annual statements, after the issuer's fiscal year ends
• b.Within 10 days after the end of the month in which the trade occurred
• c.Within two business days after the trade date✓
• d.Within four business days, the deadline for a current report on Form 8-K

Rule 16a-3(g)(1) requires a Section 16 insider to file Form 4 before the end of the second business day following the day the transaction was executed, so a Monday sale is reported by Wednesday. The annual Form 5 is for transactions not previously reported and is filed after the fiscal year ends. A monthly period was the old Form 4 deadline and no longer applies. Four business days is the Form 8-K deadline, which is a different filing by the issuer.Exchange Act Section 16(a); SEC Rule 16a-3(g)(1)

A director buys 1,000 shares at $40 and sells them at $46 four months later. What is the consequence under Section 16(b)?

• a.Nothing, because the shares were held over 90 days
• b.The director owes the SEC $6,000 as a fine
• c.The company may recover the $6,000 profit✓
• d.The sale is void and the shares return to the director

Section 16(b) lets the issuer recover profits from any purchase and sale, or sale and purchase, within a period of less than six months. The recovery here is 1,000 x $6 = $6,000 and goes to the company. The statute does not impose an SEC fine, void the trade, or exempt a four-month hold.Exchange Act Section 16(b)

An investor acquires 5.4% of a company's registered voting equity securities. What must the investor file, and when?

• a.A Schedule 13D within 45 days after the year ends
• b.A Form 4 within two business days of crossing 5%
• c.A Form 144 within ten calendar days of crossing 5%
• d.A Schedule 13D within five business days of crossing 5%✓

Beneficial ownership of more than 5% requires a Schedule 13D within five business days after the acquisition. Form 144 relates to sales by affiliates, and Form 4 is for directors, officers and 10% holders. The year-end timing applies to certain passive filers on Schedule 13G, not this deadline.Exchange Act Section 13(d)

A bidder makes a tender offer for a company's shares. For at least how long must the offer stay open?

• a.30 calendar days
• b.5 business days
• c.20 business days✓
• d.10 business days

Rule 14e-1 requires that a tender offer remain open for at least 20 business days from its commencement. Ten and five business days are too short, and a calendar-day measure is not how the rule counts.Exchange Act Rule 14e-1

An issuer's CFO unintentionally discloses material nonpublic earnings information to an analyst on a call. Under Regulation FD, when must the company make the information public?

• a.Within one hour, because the analyst may trade immediately
• b.Only if the analyst actually trades on the information
• c.By the release of the following quarter's earnings report
• d.Promptly, meaning the later of 24 hours or the next NYSE open✓

For a non-intentional selective disclosure, Regulation FD requires public disclosure promptly, defined as as soon as reasonably practicable and no later than the later of 24 hours or the start of the next day's NYSE trading. Waiting for a later earnings release is too slow, and trading by the recipient is not a condition.Regulation FD

How long must dealers deliver a prospectus after an initial public offering of a company whose stock is listed on a national exchange?

• a.25 days after the offering date✓
• b.30 days after the offering date
• c.90 days after the offering date
• d.40 days after the effective date

Rule 174(d) ends the prospectus delivery period 25 calendar days after the offering date when the issuer was not already a reporting company and its security is listed on a national exchange (or authorized for an interdealer quotation system) as of the offering date. Thirty days has no basis in the rule, and 90 days and 40 days after the effective date are longer periods that do not apply once Rule 174(d) is satisfied.Securities Act Rule 174(d), 17 CFR 230.174(d)

A registration statement is filed on March 1 and the SEC issues no stop order or acceleration. On what day does it become effective?

• a.On the 5th business day after filing
• b.On the day it is filed
• c.On the 20th day after filing✓
• d.On the 90th day after filing

Under Section 8(a) a registration statement becomes effective on the 20th day after filing unless the SEC accelerates it or delays it. Immediate effectiveness is not automatic, and neither a 90-day nor a five-business-day period appears in the statute.Securities Act Section 8(a)

An affiliate plans to sell 4,000 shares of restricted stock priced at $15 in a three-month period. Must a Form 144 be filed?

• a.Yes, because the $60,000 sale exceeds $50,000✓
• b.No, because the share count is under 5,000
• c.No, because affiliates never file Form 144
• d.Yes, but only after the sale is completed

Form 144 is required if an affiliate's sales in any three-month period exceed 5,000 shares or $50,000. Here 4,000 x $15 = $60,000, so the dollar threshold is met even though the share count is not. Affiliates are the persons the filing applies to, and the notice is filed at the time the order is placed.Securities Act Rule 144(h)

Which entity is a qualified institutional buyer for Rule 144A purposes?

• a.An individual investor who owns and invests $100 million in securities
• b.A broker-dealer that owns and invests $10 million in unaffiliated securities✓
• c.An insurance company that owns and invests $5 million in securities
• d.A broker-dealer whose total assets are $10 million on its balance sheet

A registered broker-dealer qualifies as a QIB if it owns and invests on a discretionary basis at least $10 million in securities of unaffiliated issuers. Most other institutions need $100 million. Total assets is the wrong measure, $5 million is too little, and individuals are not QIBs.Securities Act Rule 144A

Which person qualifies as an accredited investor?

• a.A single person earning $180,000 in each of the last two years
• b.A couple with $250,000 joint income in each of the last two years
• c.A person whose $1.4 million net worth includes a $600,000 home
• d.A single person with $210,000 income in each of the last two years✓

A natural person qualifies with individual income over $200,000 in each of the past two years, or $300,000 joint, with the same expected this year. Net worth must exceed $1 million excluding the primary residence, so $1.4 million with a $600,000 home is only $800,000. $180,000 and $250,000 joint fall short of the income tests.Regulation D, Rule 501(a)

What is the limit on non-accredited purchasers in a Rule 506(b) offering?

• a.35 purchasers in total, including accredited investors
• b.35, with no limit on accredited investors✓
• c.No limit if the offering is advertised generally
• d.500 non-accredited purchasers in any 12-month period

Rule 506(b) allows sales to an unlimited number of accredited investors and no more than 35 non-accredited purchasers who must be sophisticated. It is not a limit on all purchasers, 500 is not part of the rule, and general advertising is not allowed in a 506(b) offering.Regulation D, Rule 506(b)

Under FINRA's anti-money laundering rule, how often must a member firm with customer accounts have its AML program independently tested?

• a.Every two years, on the firm's fiscal-year basis
• b.Every three years by an outside accountant
• c.At least annually, on a calendar-year basis✓
• d.Only after a regulatory examination finds a deficiency

Rule 3310 requires independent testing at least annually on a calendar-year basis for firms with customer accounts. The two-year interval applies to firms that do not carry customer accounts. Testing after an exam, or every three years, is not what the rule says.FINRA Rule 3310

A broker-dealer detects a suspicious transaction of $20,000 by a known customer. By when must it file a SAR?

• a.Always 60 calendar days after detection
• b.15 business days after detection
• c.30 calendar days after initial detection✓
• d.Within 24 hours after detection

A SAR is due within 30 calendar days after initial detection of the facts. The period can extend to 60 days only when no suspect has been identified, and this customer is known. Fifteen business days and 24 hours are not the deadline.31 CFR 1023.320

A customer deposits $9,000 in cash on three consecutive days to avoid a currency transaction report. This conduct is:

• a.Structuring, a crime even when the funds are lawful✓
• b.Illegal only if the funds came from criminal activity
• c.Legal, because each deposit is below the $10,000 threshold
• d.Legal, provided the customer discloses the pattern afterward

Breaking up cash transactions to evade reporting is structuring and is a crime regardless of the source of the money. The size of each deposit does not make it lawful, disclosure afterward does not cure it, and illegal funds are not an element.31 USC 5324 (structuring)

A firm sends the same market commentary to 40 retail investors in a 30-day period. How is it classified, and what review is required?

• a.Correspondence that needs no principal approval
• b.A retail communication that a principal must approve before use✓
• c.Correspondence that a principal approves after it goes out
• d.Institutional communication that needs only filing with FINRA

Rule 2210 treats a written communication distributed to more than 25 retail investors in a 30-day period as a retail communication, and a registered principal must approve it before use. Correspondence is 25 or fewer. Institutional communications go only to institutional investors.FINRA Rule 2210

Under the Exchange Act's insider trading penalty provision, what is the maximum civil penalty for a person who trades on material nonpublic information?

• a.Ten times the dollar value of the trade itself
• b.Three times the profit gained or loss avoided✓
• c.An amount equal to the profit gained or loss avoided
• d.A flat $25,000 civil penalty for each violation

Section 21A authorizes a civil penalty of up to three times the profit gained or loss avoided. A penalty equal to profit is the disgorgement amount only, and neither a ten-times multiple nor a flat figure appears in the statute.Exchange Act Section 21A

A corporate officer adopts a Rule 10b5-1 trading plan. Before the first trade, how long must she wait under the cooling-off rule?

• a.One year after adopting the plan, regardless of her filings
• b.None, because a written plan allows trading the same day
• c.90 to 120 days, depending on when her periodic report is filed✓
• d.30 days after adopting the plan, the same as for other persons

Directors and officers must wait the later of 90 days after adoption or two business days after the 10-Q or 10-K for the quarter of adoption, capped at 120 days. The 30-day period is for other persons. A written plan does not remove the wait, and a one-year requirement does not exist.Rule 10b5-1(c)

A municipal bond is sold in a new issue. How is it treated under the Securities Act of 1933?

• a.It is exempt from both registration and antifraud provisions
• b.It is exempt only if sold solely to accredited investors
• c.It must be registered with the SEC just like a corporate bond
• d.It is exempt from registration but not from antifraud rules✓

Municipal securities are exempt securities and need no SEC registration, but the antifraud provisions still apply. Being exempt from registration does not remove liability for fraud, and the exemption does not depend on investor status.Securities Act Section 3(a)(2)

A member firm learns it has been found by a securities regulator to have violated securities laws. By when must it report the event to FINRA?

• a.By the 15th day of the month after the calendar quarter in which the finding occurred
• b.Within 30 calendar days after it knew or should have known✓
• c.Within 90 days after the fiscal year ends
• d.Within 24 hours after the firm's compliance officer learns of it

Rule 4530(a) requires a member to report promptly, and in any event not later than 30 calendar days after it knows or should have known, that it has been found to have violated securities laws by a regulator. The quarter-end 15th-day deadline belongs to the separate quarterly customer-complaint statistics under Rule 4530(d). A year-end deadline and a 24-hour deadline do not apply to this event.FINRA Rule 4530

A firm receives several written customer complaints during the third quarter. When is its quarterly statistical report due?

• a.By the 15th day of the month after the quarter ends✓
• b.Within 30 days after each complaint is received
• c.By the 15th day of the month after the year ends
• d.By the 30th day after each quarter ends

Rule 4530(d) requires statistical and summary information on written customer complaints to be reported to FINRA by the 15th day of the month following the calendar quarter in which the complaints were received. The deadline is not set by the date each individual complaint arrives, it is not an annual report, and the 30th day of the month is not the cutoff.FINRA Rule 4530(d)

A registered representative of a different FINRA member firm asks to buy shares in a hot IPO from your firm. Under the new issue rule, the sale is:

• a.Permitted if the shares are held for 30 days
• b.Prohibited, because the buyer is a restricted person✓
• c.Permitted if the buyer pays the full price in advance
• d.Permitted, because the buyer is a registered representative

Rule 5130 bars sales of new equity issues to restricted persons, a group that includes personnel of broker-dealers. Their registration does not make them eligible, and neither prepayment nor a short holding period changes that.FINRA Rule 5130

Which person is a statutory insider for Section 16 purposes?

• a.A beneficial owner of more than 10% of a registered equity class✓
• b.A bank lender that holds the issuer's unsecured promissory note
• c.A customer who receives research from the issuer
• d.A beneficial owner of exactly 5% of a registered equity class

Section 16 covers officers, directors and holders of more than 10% of a registered class of equity securities. Five percent triggers Schedule 13D but not Section 16. Receiving research or lending does not make someone an insider.Exchange Act Section 16

Under FINRA's communications rule, what is a retail communication?

• a.A communication sent to 25 or fewer retail investors in 30 days
• b.A communication sent to more than 25 retail investors in 30 days✓
• c.A communication sent to more than 10 retail investors in any 30 days
• d.A communication sent to more than 100 retail investors in 90 days

A retail communication goes to more than 25 retail investors within any 30 calendar-day period. A communication to 25 or fewer is correspondence. The other numbers are not part of the definition.FINRA Rule 2210

Which of these requires approval by a registered principal before its first use?

• a.A communication sent only to a bank or insurance company
• b.A brochure promoting the firm's mutual funds to the general public✓
• c.An internal training memo for registered representatives
• d.An email answering one customer's question about an account

A retail communication such as a public brochure must be approved by a principal before use. One-to-one answers are correspondence and are reviewed under the firm's procedures. Communications to institutional investors do not need pre-use approval, and an internal memo is not a communication to the public.FINRA Rule 2210

Which statement is prohibited in a retail communication?

• a.Actual historical performance with the required disclosures
• b.A projection that a fund will return 10% a year✓
• c.A fair comparison of the firm's fees with a competitor's
• d.A statement of a fund's stated investment objective

A retail communication may not predict or project investment performance, other than a few permitted items such as hypothetical analyses or price targets. A fund's objective, historical performance with required disclosures and a balanced comparison of fees are all allowed.FINRA Rule 2210

How long must a firm keep a record of written customer complaints?

• a.At least two years
• b.Until the account is closed
• c.At least four years✓
• d.At least six years

FINRA Rule 4513 requires a member to keep complaint records for at least four years. Two years is too short, and the rule does not tie the period to account closing.FINRA Rule 4513

Under FINRA's gift rule, what is the most a firm or representative may give one person in a year in connection with the recipient's employer's business?

• a.$300 per person per year✓
• b.$500 per person each year
• c.$100 per person in any year
• d.$250 per person a year

Rule 3220 caps gifts at $300 per person per year when they relate to the recipient's employer's business (raised from $100 effective March 30, 2026). The $100 figure is the pre-2026 limit and no longer applies, $250 is not a figure in the rule, and $500 is above the cap, so a gift of that size would violate it.FINRA Rule 3220(a)

At what times may a registered representative make telemarketing calls to a residence?

• a.Between 8 a.m. and 9 p.m. at the called person's home✓
• b.Between 9 a.m. and 5 p.m. at the called person's own home
• c.Between 7 a.m. and 10 p.m. at the called person's home
• d.Between 8 a.m. and 9 p.m. at the firm's home office location

Telemarketing calls are limited to 8 a.m. to 9 p.m. local time at the called person's location. The caller's time zone is not the test, and the other windows are not those in the rule.FINRA Rule 3230

A corporate director buys 1,000 shares of her company and sells them four months later at a profit. What must she do with the profit?

• a.Return it to the issuer, since the trades fell within six months✓
• b.Keep it, provided she reports both trades on Form 4
• c.Keep it, because she held the shares longer than 30 days
• d.Pay it to the SEC, which distributes it to the company's shareholders

Section 16(b) makes insiders (directors, officers and 10% owners) give back to the issuer any profit from a purchase and sale, or sale and purchase, within six months. Holding beyond 30 days does not help, the recovery goes to the issuer rather than to the SEC or shareholders directly, and filing a report does not excuse the profit.Securities Exchange Act of 1934 Section 16(b)

A broker-dealer files a suspicious activity report after detecting facts that may require one. What is the filing deadline?

• a.10 calendar days from the initial detection of the facts
• b.60 calendar days from detection of the facts
• c.30 calendar days from initial detection of the facts✓
• d.The end of the quarter in which the facts were detected

A SAR is due no later than 30 calendar days after the firm first detects facts that may constitute a basis for filing, and longer if no suspect is identified. Shorter and longer fixed periods and quarter-end filing do not match the rule.Bank Secrecy Act and 31 CFR 1023.320

A registered representative learns that the firm has filed a SAR on a customer. What may the representative do?

• a.Warn the customer so the customer can explain the activity
• b.Tell no one outside authorized firm personnel, customer included✓
• c.Share it with another customer in a similar situation
• d.Give the customer a copy so the filing can be disputed

SARs are confidential, and disclosing a filing or its existence to the subject is a violation known as tipping off. Warning, giving a copy or sharing with another customer would reveal the report.Bank Secrecy Act and 31 CFR 1023.320

For a broker-dealer, what is the dollar amount at which a suspicious transaction must be reported on a SAR?

• a.At least $25,000 in funds or assets
• b.At least $5,000 in funds or other assets✓
• c.At least $1,000 in funds or assets
• d.At least $10,000 in funds or assets

A broker-dealer must file a SAR when a transaction involves or aggregates at least $5,000 in funds or assets and the firm suspects it falls within the listed categories. The $10,000 amount is the currency transaction reporting threshold, and the other figures are not the SAR threshold.31 CFR 1023.320

How long must a broker-dealer keep a copy of a SAR and its supporting documents?

• a.Five years from the date of the filing✓
• b.Seven years from the date of the filing
• c.Three years from the date of filing
• d.Until the customer's account has been closed

A SAR and its supporting documentation must be kept for five years from filing. Three years is shorter than required, seven years is longer than the rule, and the life of the customer's account is not the measure.Bank Secrecy Act recordkeeping

Under MSRB Rule G-37, how much may a municipal finance professional contribute to a candidate they can vote for without triggering the ban on municipal business?

• a.$250 per election✓
• b.$25 per election
• c.$100 per year
• d.$1,000 per election

Rule G-37 lets a municipal finance professional give up to $250 per election to an official for whom the person can vote, and a larger amount triggers a two-year ban on negotiated business with that issuer. A $1,000 gift would trigger the ban. The $100 and $25 figures are not the limit, since the de minimis amount is per election, not per year.MSRB Rule G-37

An issuer's officer unintentionally gives material nonpublic information to an analyst. How soon must the issuer make public disclosure?

• a.Promptly, within 24 hours or by the next NYSE open, if later✓
• b.Within five business days, in the issuer's next periodic report
• c.At the next annual meeting of shareholders, in the proxy statement
• d.Within 10 days, by filing a current report on Form 8-K with the SEC

For a non-intentional selective disclosure, Regulation FD requires prompt public disclosure, meaning as soon as reasonably practicable and within the later of 24 hours or the next opening of NYSE trading. The longer periods are not allowed.Regulation FD

Which sharing of customer information requires the firm to give the customer an opportunity to opt out?

• a.Selling customer names and balances to an unaffiliated marketing firm✓
• b.Sending a copy to the customer's accountant at the customer's own written request
• c.Responding to a subpoena or document request from a regulator
• d.Sending account details to the clearing firm to carry out a trade

Sharing nonpublic personal information with a nonaffiliated company for its own marketing requires notice and a chance to opt out. Processing transactions, complying with legal process and acting at the customer's direction are exceptions.Regulation S-P

Which describes churning?

• a.Selling from the firm's inventory at a markup above the market
• b.Excessive trading in a customer account to generate commissions✓
• c.Trading ahead of a customer order using knowledge of it
• d.Recommending a security without giving a prospectus

Churning is trading that is excessive in size or frequency in light of the customer's objectives, done to earn commissions. Trading ahead of a customer order is front running, an excessive markup is a pricing violation, and prospectus delivery is a separate rule.Securities Exchange Act of 1934

A firm terminates a registered representative. By when must the firm file Form U5?

• a.Within 30 days after termination✓
• b.Within 60 calendar days after termination
• c.Within 10 business days after termination
• d.Within 90 calendar days after termination

Form U5 must be filed within 30 days after the representative's registration is terminated. Ten business days is shorter than the by-law requires, while 60 and 90 days would let the filing run past the deadline.FINRA By-Laws Article V

How long after a representative's registration terminates does FINRA keep jurisdiction to bring a disciplinary complaint?

• a.Six months
• b.Two years✓
• c.One year
• d.Five years

Under the by-laws FINRA keeps jurisdiction over a former registered person for two years after the effective date of termination. Six months, one year and five years are not that period.FINRA By-Laws Article V

A representative recommends a security because the firm pays a larger bonus for selling it. Which obligation is most directly at issue?

• a.The duty to settle each trade within one business day of execution
• b.The duty to give a prospectus before any sale
• c.The duty to put the customer's interest ahead of the firm's✓
• d.The duty to amend Form U4 within 30 days of a change

Recommending a product mainly for the bonus is a conflict of interest, which the best-interest standard requires the firm and representative to address by putting the customer first. Prospectus delivery, settlement and U4 amendments are unrelated to why the product was chosen.Regulation Best Interest

How often must a member firm inspect a non-supervisory branch office under FINRA Rule 3110(c)?

• a.At least every two years, alternating with the OSJ inspection
• b.At least every three years, which is less often than an OSJ✓
• c.At least once each calendar year, the same as an OSJ
• d.At least every five years, unless a customer complaint is received

Offices of supervisory jurisdiction and supervisory branch offices must be inspected at least annually, while non-supervisory branch offices are inspected at least every three years. Annual, biennial and five-year intervals do not match the rule for this type of office.FINRA Rule 3110(c)

A customer files an arbitration claim in 2026 over a recommendation made in 2018 and argues the loss was discovered only in 2025. Under the Code of Arbitration Procedure, the claim is:

• a.Eligible, because the six-year period runs from the date the customer discovered the loss
• b.Ineligible for FINRA arbitration, because six years have passed since the event itself✓
• c.Eligible, because the time limit applies only to disputes between two FINRA member firms
• d.Eligible, because the customer's account at the firm remained open all that time

Rule 12206 makes a claim ineligible when six years have elapsed from the occurrence or event giving rise to it. The period runs from the event, not from discovery of the loss, and neither an open account nor the identity of the parties extends it.FINRA Rule 12206

A registered representative wants to borrow $10,000 from a customer who is her sister. Under FINRA Rule 3240, what is required?

• a.Firm written procedures must allow such loans, and may waive notice and approval for immediate family✓
• b.Written pre-approval from the firm in every case, because the rule has no family exception
• c.Nothing, because loans between immediate family members fall outside the rule
• d.Only that the loan be on commercial terms offered to the public; no written procedures are needed

Rule 3240(a)(1) bars borrowing from or lending to a customer unless the firm has written procedures allowing it, and the arrangement must fit a category in (a)(2), one of which is a customer who is an immediate family member, including a sister. For that category, (b)(2) lets the firm's procedures dispense with notice and approval. Arrangements based on a personal or business relationship need notice and written pre-approval. The rule does have a family category, so family loans are not exempt from the rule itself and the written-procedures condition still applies. The commercial-terms condition belongs to loans from financial institutions that lend in the ordinary course of business, and there is no repayment-period or Form U4 requirement.FINRA Rule 3240(a)(2)(A), (b)(2)

A firm emails the same written market commentary to 40 retail investors over a 30-day period. FINRA Rule 2210 classifies this communication as:

• a.Correspondence, because it was sent by email and not mailed
• b.Institutional communication, because it was sent only to existing customers of the firm
• c.Public appearance, because it reached more than 25 recipients
• d.Retail communication, because it went to over 25 retail investors in 30 days✓

Correspondence is written material sent to 25 or fewer retail investors within any 30-calendar-day period; anything sent to more is a retail communication, with its own approval and content standards. Email is a written medium either way, the recipients are retail and not institutional investors, and a public appearance is an interactive event such as a seminar.FINRA Rule 2210

In March a representative gives a client's employee a $200 watch, and in October gives the same person a $125 pen set. Both gifts relate to the firm's business. Under Rule 3220:

• a.The gifts violate the rule, because the two total $325, over the $300 annual limit✓
• b.The gifts violate the rule only if the employee reports them to FINRA or the employer
• c.The gifts comply, because each gift on its own is below the $300 annual limit
• d.The gifts comply, because gifts given in different months are measured separately by the firm

Rule 3220 prohibits giving anything of value over $300 per individual per year in relation to the business of the recipient's employer. The limit applies to the total for one person in the year, so $200 plus $125 is $325 and exceeds it. Splitting the gifts by amount or by month does not avoid the aggregate test, and the rule does not depend on the recipient reporting anything.FINRA Rule 3220

Each calendar quarter, a member must report statistical information about written customer complaints to FINRA. When is it due?

• a.Within 10 days of each individual complaint's receipt
• b.Within 30 days after the end of that calendar quarter
• c.By the 15th day after the end of the quarter✓
• d.By the last business day of the quarter itself

Rule 4530(d) requires quarterly statistical and summary complaint information to be filed by the 15th day of the month following the calendar quarter. The 30-calendar-day period applies to reports of certain specified events under another part of the rule, not to the quarterly statistics, and the filing is not made complaint by complaint.FINRA Rule 4530(d)

A broker-dealer detects facts on March 3 that may require a SAR, and a suspect has been identified. By what date must the SAR be filed?

• a.May 2, which is the 60-day maximum allowed
• b.April 17, a deadline set at 45 calendar days
• c.April 2, which is 30 days after initial detection✓
• d.March 18, a deadline set at 15 calendar days

A SAR must be filed no later than 30 calendar days after the date of initial detection of facts that may constitute a basis for filing. If no suspect has been identified, the deadline may extend to a maximum of 60 days. March 3 plus 30 days is April 2. The other dates reflect periods that are not in the rule or apply only when no suspect is identified.31 CFR 1023.320

A customer delivers $6,500 in currency to a broker-dealer in the morning and $4,500 in currency in the afternoon of the same business day. What must the firm do?

• a.File a CTR within 30 days, after the second delivery is processed and the books close
• b.File a CTR within 15 days, because the two deliveries are aggregated and total over $10,000✓
• c.File only a Suspicious Activity Report, because the customer split the delivery into two parts
• d.File nothing, because neither transaction alone exceeds the $10,000 currency reporting threshold

Currency transactions by or for one person in a single business day are aggregated, and a CTR is required when the total exceeds $10,000. Here it is $11,000, and the report is due within 15 days. Each delivery below the threshold individually does not matter, 30 days is the SAR deadline, and a SAR does not replace a required CTR.31 CFR 1010.311