Introduction
Welcome to Customer Investment Profiles and Suitability: the rules that tell a Series 6 representative what to ask, who the answers are for, and which standard of care applies when a recommendation gets made.
Exam Weight: Part of 16% (8 questions across Chapter 2)
What You'll Learn
In this unit, you'll cover:
- The Customer Investment Profile: The financial and non-financial facts a registered representative (rep) must make reasonable efforts to gather, and why refusing to share information limits what the rep can recommend
- FINRA Rule 2111 (Suitability): The three-layer test (reasonable-basis, customer-specific, quantitative) and the investment-profile factors listed in Rule 2111(a)
- Hold Recommendations and Strategy Recommendations: Why a "stay in that fund" comment is itself a recommendation, and which educational safe harbors fall outside Rule 2111
- The Institutional-Customer Exemption (Rule 2111(b)): When a $50 million customer affirmatively exercising independent judgment waives customer-specific suitability
- Regulation Best Interest (SEA Rule 15l-1): The four obligations (Disclosure, Care, Conflict of Interest, Compliance) that apply to recommendations to retail customers
- Form CRS (SEA Rule 17a-14): The relationship summary, its page limits, the five required sections, and the delivery triggers for new and existing retail investors
- FINRA Rule 2214 (Investment Analysis Tools): The required written narrative disclosures and the 10-business-day filing and access obligations
- MSRB Rule G-19: The municipal-securities suitability parallel that governs 529 plans, Local Government Investment Pools (LGIPs), and Achieving a Better Life Experience (ABLE) accounts
Why This Matters
The Series 6 exam tests whether you can tell:
- KYC vs. Suitability: Rule 2090 (Know Your Customer, KYC) always applies; Rule 2111 only applies when a recommendation is made
- Three cumulative obligations: a recommendation must pass reasonable-basis, customer-specific, and quantitative suitability (not any one of them)
- Hold = recommendation: telling a customer "keep holding" is itself a recommendation subject to suitability
- Reg BI covers retail only: recommendations to institutional customers stay under FINRA Rule 2111
- Form CRS is broader than Reg BI: a prospect who has not received a recommendation is still a retail investor for Form CRS delivery
- Sales contests must be eliminated, not disclosed: the Conflict of Interest Obligation under Reg BI treats them as a category that disclosure cannot cure
Every fact protects the customer, supports the recommendation file, and documents your defense if a complaint is filed later.
Let's start with the information the rep must gather before any recommendation is made.