Quick Answer
A change to any required account-record item, such as an address, associated person, or tax ID, obligates the firm to update its record, starting a fresh six-year retention clock. A firm need not bring a prior-rule account into full compliance until it next updates that information. Reassigning an account to a different associated person is itself a recordkeeping event.
Account records are not static once filed. Anything that changes the facts the firm relied on to open the account triggers a duty to update, and that duty reaches further than a simple address change.
What Triggers an Update to the Account Record?
- A change to any required customer account information item (address, associated person, tax identification number, and so on) obligates the firm to update its account record.
- A firm is not required to bring an account opened under a prior rule into full compliance with the current account information requirements until the firm updates that account's information, either in the ordinary course of business or as otherwise required by applicable laws or rules.
- Once the firm updates the record, the six-year retention clock covered earlier in this unit applies to the update. That clock runs from the date of this update, not from the date the account was originally opened.
- That first update also pulls in the trusted contact person disclosure. A firm that updates a legacy account's information must give the customer that written disclosure at the same time.
Think of it this way: an account opened years ago under an older requirement is not automatically deficient today. The firm's obligation to bring it current attaches the moment the firm touches that account's record again, not before.
What Happens When Responsibility for an Account Moves Internally?
- Reassigning an account to a different associated person within the firm requires updating the account record identifying the associated person(s) responsible for the account.
- If responsibility for the account is shared among multiple associated persons, the record must show the scope of each person's responsibility, and that scope must be kept current as responsibility shifts.
Exam Tip: Gotchas
- A registration change is not just a name or address edit. Moving responsibility for an account to a different associated person inside the firm is itself a recordkeeping event that requires updating the record.
What Should You Check on Exam Day?
- Identify whether a fact pattern describes a customer-driven change (address, tax ID) or a firm-driven change (internal reassignment); both trigger the same update duty.
- Confirm that an older account is not automatically out of compliance; compliance attaches at the next update, not retroactively.
- Watch for shared-responsibility fact patterns: the scope split must stay current, not just recorded once at account opening.