Quick Answer
Refusing an account runs through the firm's principal-level supervisory approval, never the representative's judgment: without a principal's documented acceptance, it cannot open. Closing is not assigned that way, so a firm handles it under its written procedures. A failed identity check can force either outcome, and a suspicious activity report may still be owed.
Three related questions live here: who can refuse an account, who can close one, and when does a failed identity check force that decision.
Who Has the Authority to Refuse an Account?
- Because the account record must carry a principal's signature denoting acceptance under the firm's policies and procedures for accepting accounts, a principal who will not sign has, in effect, refused the account. It cannot open without that documented approval.
Who Has the Authority to Close an Account?
- Nothing in this topic assigns the closing decision the way the acceptance signature assigns the opening one. A firm decides how an existing account relationship ends under its own written supervisory procedures, so look for what those procedures say rather than for a named decision maker.
- The one closing the rules do reach is the failed identity check below: a firm's customer identification program should describe when the firm should close the account after verification attempts fail.
Exam Tip: Gotchas
- A representative cannot unilaterally open a customer account. Opening runs through the firm's principal-level supervisory approval, not the representative's own judgment. Do not carry that over to closing: the firm's own written procedures govern how an account relationship ends.
When Does a Failed Identity Check Force the Decision?
- The firm's customer identification program must include written
procedures for the case where the firm cannot form a reasonable belief
that it knows the customer's true identity. Having the procedures is
mandatory; their contents are stated more softly, as the rule says they
should describe:
- when the firm should not open the account;
- the terms on which a customer may transact while verification is still pending;
- when the firm should close the account after verification attempts fail; and
- when the failure should lead the firm to file a suspicious activity report (SAR).
- A different unit in this course covers what the firm must collect and how it verifies a customer's identity in the first place; this topic covers only the failure branch of that same process.
Exam Tip: Gotchas
- A failed identity check is not only an account decision. The same procedures decide whether the firm must file a suspicious activity report, so refusing the account does not end the firm's duty.
What Should You Check on Exam Day?
- Confirm an account opening ran through a principal's documented acceptance, never the representative alone, and that a closing followed the firm's own written procedures.
- Confirm a firm's identity-verification procedures address all four outcomes: not opening, transacting while pending, closing after failed verification, and filing a suspicious activity report.
- Do not assume refusing or closing an account after a failed identity check ends the analysis; a suspicious activity report may still be required.