Account Registration Changes and Internal Transfers

With your understanding of account types, registration, and wealth events complete, you can now learn the rules governing changes to existing accounts: name changes, transfers between firms, and re-registration.

FINRA Rule 4515 - Changes in Account Name or Designation

• No change in account name(s) or designation(s) may be made unless authorized by a qualified and registered principal
• The principal must be personally informed of the essential facts before granting approval
• Approval must be indicated in writing on the order or similar record
• The essential facts relied upon must be documented in writing and preserved per SEC Rule 17a-4(b)

Pre-Execution Changes

• For changes made before trade execution: documentation must be completed prior to execution
• This ensures no trades occur under incorrect account designations

Exam Tip: Gotchas

• Only a principal can approve account name/designation changes, not the registered representative (RR). The principal must be personally informed of the facts and give written approval.
• Pre-execution changes must be documented before the trade executes. If the documentation comes after, it is a violation.

ACAT Transfers (Automated Customer Account Transfer System)

ACAT is the industry system for transferring customer accounts between broker-dealers. It is operated by the National Securities Clearing Corporation (NSCC).

Transfer Timeline

• Total timeline: Typically 4-6 business days from initiation to completion
• Both partial transfers (specific securities) and full account transfers are permitted
• Customers can also request internal transfers within the same firm (e.g., re-registration from individual to joint)

Exam Tip: Gotchas

• ACAT transfers must be completed within 3 business days after validation, not 3 business days from the initial request. The delivering firm gets 1 business day to validate first, so the total minimum timeline is 1 + 3 = 4 business days from initiation.
• The receiving firm initiates the ACAT transfer, not the delivering firm. The customer signs the Transfer Initiation Form (TIF) at the new firm.

Re-Registration Requirements

• Moving assets between accounts at the same firm (e.g., from an individual account to a trust) requires principal approval under Rule 4515
• Supporting documentation must be obtained:
  • Trust documents for transfer to a trust account
  • Death certificate and letters testamentary for estate transfers
  • Marriage certificate or court order for name changes
• The firm must update its records to reflect the new registration and provide the customer with an updated account record

Exam Tip: Gotchas

• Re-registration at the same firm still requires principal approval under Rule 4515, plus supporting documentation (trust documents, death certificate, court order, etc.). Moving assets between your own accounts is not a simple request.