Introduction

Welcome to Customer Communications and Records: the paper trail that proves every Series 6 recommendation actually happened the way it was supposed to. Unit 9 covered what the rep must tell the customer at the point of sale. This unit covers what the firm must send the customer after the sale, what records the firm must keep internally, and how accounts move between firms when a customer leaves.

Exam Weight: Part of 50% (25 questions across Chapter 3)

What You'll Learn

In this unit, you'll cover:

• Customer Confirmations: Trade confirmations under Securities Exchange Act (SEA) Rule 10b-10, Financial Industry Regulatory Authority (FINRA) Rule 2232, and Municipal Securities Rulemaking Board (MSRB) Rule G-15, including capacity disclosure, remuneration, and third-party mailing rules
• Customer Account Statements: Quarterly delivery under FINRA Rule 2231, realized vs. unrealized gains, the delivery-versus-payment / receipt-versus-payment (DVP/RVP) exception, and third-party duplicate-delivery requirements
• Customer Account Records and Required Notifications: FINRA Rule 4512 customer account information, change-of-address procedures, Trusted Contact Person (TCP) updates, and investment objective changes
• Books and Records Retention Requirements: SEA Rules 17a-3 and 17a-4, the 6-years / 3-years framework, customer account records preserved for 6 years after account closing, MSRB Rules G-8 and G-9, and SEA Rule 17a-8 Bank Secrecy Act (BSA) cross-references
• Customer Account Transfers (ACATS): FINRA Rule 11870 and MSRB Rule G-26, the 1-business-day validate plus 3-business-day complete timeline, and variable annuity transfer mechanics
• Educational Communication on Recruiting (FINRA Rule 2273): The FINRA-prepared educational communication delivered to former customers of a recruited rep for 3 months after the rep joins
• Account Closure Procedures: Customer-initiated closure, inactive-account closure, dormant and escheated accounts, and post-closure retention obligations

Why This Matters

Function 3.4 is the recordkeeping spine of Series 6. Every trade the rep executes creates a chain of documents:

• Confirmation to the customer
• Statement showing the position
• Internal record of the transaction
• Retention of that record for a regulatory period

A rep who does not understand which document must reach the customer by when, and which records the firm must preserve for 6 years vs. 3 years, cannot spot the three most common customer-complaint scenarios:

• A missing confirmation disclosing capacity
• A late or missing account statement
• A transfer request that the carrying firm has not acted on within the ACATS window

The Series 6 exam tests whether you can:

• Name the confirmation and statement delivery triggers: at or before completion of the transaction (10b-10 / 2232); at least quarterly (2231)
• Distinguish agent from principal capacity: commission vs. markup / markdown; net transactions require express "net" labeling
• Apply the 6-year / 3-year retention framework: core records and customer account records = 6 years; order tickets, confirmations, and communications = 3 years; first 2 years easily accessible in both tiers
• Recognize the 6-years-after-closing rule: customer account records do not start their retention clock at account opening
• Walk the ACATS timeline: 1 business day to validate, 3 business days to complete, 6-month residual-position handling
• Identify a Rule 2273 trigger: a rep's former customer is contacted about transferring assets during the 3-month window after the rep's new-firm hire

The sections below walk the records lifecycle in order: first the documents that travel to the customer (confirmation, statement, account-record notifications), then the records the firm preserves internally (the 17a-3 / 17a-4 framework), then the scenarios that move accounts between firms (ACATS transfer, recruiting, closure).

Let's start with the document that lands on the customer's desk first: the trade confirmation.