Section 3 Understanding Trading, Customer Accounts and Prohibited Activities

Customer Accounts: Types and Requirements

22 min read · Lesson 4 of 10

About This Lesson

Customer accounts generate a heavy share of SIE questions, usually framed as "which account fits this customer" or "is this allowed." The two areas that carry the most weight are the different account types and ownership structures, and the mechanics of a margin account, where the numbers and the rules both get tested.

What you'll cover

  • Account types: cash, margin, options, discretionary, and fee-based
  • Ownership and registration: individual, joint (JTWROS and TIC), trust, and custodial
  • What a firm must collect to open an account, and the extra steps by account type
  • Margin mechanics: Regulation T, equity, maintenance requirements, and margin calls
  • Short selling, non-marginable securities, and the minimum to open a margin account

Two reflexes worth building now: discretion over what, how much, or whether to trade needs written authorization (picking only the time or price does not), and JTWROS passes a deceased owner's share to the survivors while TIC sends it to the estate.

Section 1 of 4 ~4 min · 1 concept check

Account Types

The first thing a new account establishes is how the customer will pay and what the firm is allowed to do on their behalf. A handful of account types cover almost everything the exam asks about.

  • Cash account: the customer pays in full for every purchase. No borrowing, and the simplest, most common type.
  • Margin account: the customer can borrow part of the purchase price from the broker-dealer, using the securities as collateral. It is governed by the Federal Reserve's Regulation T, covered in detail later in this chapter.
  • Options account: requires separate approval, delivery of the Options Disclosure Document (ODD), and a signed options agreement, because options carry risks a plain stock account does not.
  • Discretionary account: the customer gives the broker written authority to trade without checking in on each order. That written authorization is the defining requirement.

Fee-based vs. commission

Accounts also differ in how the firm charges. A commission account bills per transaction, which suits a buy-and-hold investor who trades rarely. A fee-based account (such as a wrap account) charges a flat fee or a percentage of assets instead, which tends to fit a more active investor. Matching the pricing to how often the customer trades is a common suitability point.

Discretionary vs. Non-Discretionary: If a broker chooses the asset, amount, or action (buy/sell) without customer input, it's discretionary and requires written power of attorney. Choosing only the time or price of execution is NOT discretionary.
Account Types. Key Requirements at a Glance
Cash Account Margin Account Options Account UGMA/UTMA Custodial
Pay in full?Yes, full paymentNo, 50% Reg TYes, premiums paid in fullYes
Can borrow?NoYes, up to 50%No (cash account for options)No
Short selling allowed?NoYesNo (requires margin)No
Special agreements requiredNew account formMargin agreement + hypothecation agreementOptions agreement (signed within 15 days); ODD deliveredCustodian designated; minor's SSN
Who controls trading?Account ownerAccount ownerAccount owner (ROP approval)Custodian only, not the minor
Gift/irrevocable?NoNoNoYes, irrevocable gift to minor
Can minor access funds?N/AN/AN/AAt age of majority (18 or 21 by state)
Margin calls possible?NoYesNoNo
Free-riding violation possible?Yes, 90-day freezeNoYesYes

UGMA/UTMA exam traps: (1) Only ONE custodian and ONE minor per account. (2) The gift is irrevocable: assets cannot be returned to the donor. (3) The custodian controls the account, not the minor. (4) No margin or naked options in custodial accounts.

Concept Check

A customer gives their broker the authority to buy 500 shares of XYZ stock, but lets the broker decide when to execute the trade. Is this considered a discretionary order?

Choosing only the time and/or price of execution when the customer has specified the asset, action, and amount is NOT considered discretionary. Discretion applies when the broker chooses what to buy/sell, how much, or whether to buy or sell.
Section 2 of 4 ~5 min · 2 concept checks

Account Ownership and Registration

Ownership, also called the account registration, determines who controls the assets and, importantly for the exam, what happens to them when an owner dies.

Individual and joint accounts

An individual account has a single owner. A joint account has two or more, and the form of joint registration decides where a deceased owner's share goes:

  • Joint Tenants with Right of Survivorship (JTWROS): when one owner dies, that share passes directly to the surviving owner(s) and bypasses probate. Each owner holds an equal, undivided interest, which is why this is the common choice for spouses.
  • Tenants in Common (TIC): when one owner dies, that share goes to their estate rather than to the other owners, and ownership percentages can be unequal.

Trust accounts

A trust account is managed by a trustee for the benefit of a beneficiary, and the trustee must follow the terms of the trust document. A revocable trust can be changed or dissolved by the grantor; an irrevocable trust cannot be altered once it is established.

Custodial accounts (UGMA and UTMA)

A custodial account lets an adult custodian manage assets for a minor. The contribution is an irrevocable gift: it belongs to the minor and cannot be taken back. There is exactly one custodian and one minor per account, and no margin or options trading is allowed. The minor takes full control at the age of majority, 18 or 21 depending on the state (UTMA can run somewhat later). The difference between the two is scope: UGMA (Uniform Gifts to Minors Act) holds a narrower set of assets, while UTMA (Uniform Transfers to Minors Act) allows a broader range.

JTWROS vs. TIC, The Estate Difference:

Joint Tenants with Right of Survivorship (JTWROS): When one owner dies, their share passes directly to the surviving owner(s): bypasses probate. Each owner has an equal, undivided interest.

Tenants in Common (TIC): When one owner dies, their share passes to their estate/heirs (NOT to the other account holders). Owners can have unequal ownership percentages.

Exam trap: Community property states have different rules, but the SIE focuses on JTWROS vs. TIC.
Concept Check

In a Joint Tenants with Rights of Survivorship (JTWROS) account, if one owner dies, what happens to their share?

In a JTWROS account, when one owner dies, their share passes directly to the surviving owner(s), it does NOT go through the estate. This is the key difference from Tenants in Common (TIC), where the deceased's share goes to their estate.
Concept Check

A customer opens a UGMA account for their 10-year-old daughter and contributes $20,000. Which of the following statements is correct?

UGMA/UTMA custodial accounts hold assets as an irrevocable gift to the minor. The minor gains full control at the age of majority (18 or 21 depending on state). The gift cannot be reclaimed by the donor. Only one custodian is allowed per account. Options and margin trading are not permitted in custodial accounts.
Section 3 of 4 ~4 min

Opening an Account

Before any account is opened, the firm has to gather enough information to know who the customer is and whether what they want to do is suitable. This pulls together the identity rules of the Customer Identification Program with the financial picture a representative needs.

What goes on the new account form

  • Full name and date of birth
  • Social Security number or tax ID
  • Address and phone number
  • Citizenship status
  • Employment status and employer
  • Annual income and net worth
  • Investment objectives (growth, income, speculation, preservation) and risk tolerance
  • Whether the customer works for a FINRA member firm or a public company, which flags a restricted person

Extra steps by account type

  • Margin account: a signed margin agreement, a credit check, and a hypothecation agreement that lets the firm pledge the customer's securities as collateral for the loan.
  • Options account: the ODD delivered at or before approval, registered options principal (ROP) approval, and a signed options agreement returned within 15 days.
  • Custodial account: one custodian and one minor, with all assets held as an irrevocable gift to the minor, and no margin or options.
  • Corporate or partnership account: a corporate resolution or partnership agreement showing who is authorized to trade.
📋 Put It In Order: Opening a New Customer Account
Put It In Order
Arrange the steps of opening a new brokerage account in the correct regulatory order, from first contact to first trade.
💡 Desktop: drag to reorder. Mobile: tap two items to swap them.
    ✅ Correct Order
    The account opening sequence is driven by compliance requirements: CIP first (you must know who the customer is before anything else), then suitability data collection, then disclosures, then documentation, then approval, then trading. Skipping or reordering these steps is a compliance violation. The principal approval requirement ensures supervisory oversight before any activity begins.
    Section 4 of 4 ~9 min · 4 concept checks

    Margin Accounts

    A margin account lets a customer borrow part of a purchase from the broker-dealer, with the securities in the account serving as collateral for the loan. Two numbers anchor everything the SIE tests: the initial deposit and the account's equity.

    Regulation T: the initial deposit

    Set by the Federal Reserve Board, Regulation T requires the customer to put up at least 50% of the purchase price. Buy $20,000 of stock on margin and you must deposit $10,000; the broker lends the other $10,000.

    Equity

    Your stake in the account is its equity:

    Equity = market value − debit balance

    On that $20,000 purchase, the market value is $20,000, the debit balance (the loan) is $10,000, and your equity is $10,000, exactly the 50% Reg T required. The equity percentage is simply equity divided by market value.

    Margin Account: How It Works Day 1: Purchase $20,000 Stock Market Value: $20,000 Your Equity $10,000 (50%, Reg T) Broker Loan $10,000 (Debit Balance) Stock drops 40% After Drop: Worth $12,000 Market Value: $12,000 Equity: $2,000 (16.7%) Broker Loan $10,000 (unchanged) ⚠ MARGIN CALL, Below 25% maintenance

    Putting up the initial 50% is only the start. Once the position is on, the account has to keep a minimum level of equity, and that is where margin calls come from.

    • FINRA minimum maintenance is 25% of current market value for a long position.
    • Most firms set a stricter house maintenance requirement, typically 30 to 35%.
    • If equity falls below the requirement, the firm issues a margin call (a maintenance call). The customer has to deposit cash or securities, or the firm can sell positions to restore the equity, and it can do so without notifying the customer first.

    Why equity shrinks

    When the stock falls, the market value drops but the loan (the debit balance) does not, so equity absorbs the entire loss. Say that $20,000 position falls to $14,000: equity is now $14,000 − $10,000 = $4,000, or 28.6% of market value. That clears the 25% FINRA floor but would trip a 30% house call.

    The trigger price

    You can find the price at which a long position hits a maintenance call directly:

    Trigger price = debit balance ÷ (1 − maintenance %)

    With a $10,000 debit and 25% maintenance, that is $10,000 ÷ 0.75 = about $13,333. Once the market value falls to roughly $13,333, the call goes out.

    Margin Risk: Margin amplifies both gains AND losses. If the stock rises, the investor profits on the full $20,000 position with only $10,000 invested (leverage). But if the stock falls far enough, the investor can lose MORE than their initial deposit. The Margin Disclosure Statement (FINRA Rule 2264) must be provided to all margin customers. It warns that the firm can sell securities without contacting the customer, and the customer can lose more than their initial investment.

    Selling short, borrowing shares to sell now in the hope of buying them back cheaper, can only be done in a margin account, never a cash account.

    • Regulation T still requires a 50% deposit on a short sale.
    • FINRA minimum maintenance for a short position is 30% of current market value, higher than the 25% for long positions.
    • The risk is theoretically unlimited, because there is no ceiling on how high the borrowed stock's price can climb.
    • While short, the seller owes any dividends the stock pays to the lender of the shares.

    Some securities are too volatile or too new to buy on credit, so they have to be paid for in full in a cash account:

    • Options, whose premiums must be paid in full
    • Mutual funds, for the first 30 days after purchase
    • New issues and IPOs, also for the first 30 days
    • Penny stocks, meaning stocks trading under $5 over the counter

    Separately, FINRA sets a floor on getting into margin at all: a minimum equity of $2,000 (or 100% of the purchase price, whichever is less) is required to open a margin account.

    ✏️ Worked Example: Margin Equity & Maintenance
    Worked Example
    A client buys 100 shares at $100/share in a margin account with the standard Reg T 50% initial requirement. The stock drops to $60. Calculate the current equity and determine if a margin call is triggered (25% maintenance).
    Equity = Market Value − Debit Balance
    ✓ Answer
    Equity: $1,000 (16.7%). Margin call: yes, client must deposit $500.
    Interactive: Margin Safety Simulator

    Enter your position and see exactly when a margin call triggers. Practice with real scenarios before the exam.

    Open Tool →
    📉 Scenario: Margin Call
    Scenario Walkthrough
    👤 Client: David Thompson, 41, Small Business Owner
    David buys 200 shares of XYZ Corp at $80/share using a margin account with the standard Regulation T requirement of 50%. The stock drops sharply. Walk through what happens to David's position.
    Step 1 of 4
    ✅ Scenario Complete
    • Reg T = 50% initial margin requirement. Customer deposits half, broker-dealer lends half.
    • Equity = Market Value − Debit Balance. The loan stays constant; equity absorbs all gains and losses.
    • Minimum maintenance = 25%. If equity falls below this, a margin maintenance call is issued.
    • Margin amplifies both gains and losses. David's equity fell 75% on a 37.5% stock decline.
    • If you don't meet a margin call, the broker-dealer can liquidate your securities without permission.
    Concept Check

    Under Regulation T, an investor purchasing $30,000 of stock in a margin account must deposit a minimum of:

    Regulation T, set by the Federal Reserve, requires a minimum initial deposit of 50% of the purchase price for margin transactions. 50% of $30,000 = $15,000. The remaining $15,000 is borrowed from the broker-dealer (the debit balance).
    Concept Check

    An investor buys $30,000 of stock in a margin account under Regulation T. How much must the investor deposit?

    Regulation T requires an initial margin deposit of 50% of the purchase price. 50% × $30,000 = $15,000. The remaining $15,000 is borrowed from the broker-dealer (the debit balance). Regulation T is set by the Federal Reserve Board.
    Concept Check

    Which of the following securities CANNOT be purchased on margin?

    Options premiums must be paid in full, they cannot be purchased on margin. Other non-marginable securities include mutual funds during the first 30 days, IPOs during the first 30 days, and penny stocks (under $5). Listed stocks, Treasuries, and corporate bonds are generally marginable.
    Concept Check

    An investor's margin account has a market value of $18,000 and a debit balance of $10,000. The firm's maintenance requirement is 25%. Is a margin call required?

    Equity = Market value − Debit balance = $18,000 − $10,000 = $8,000. Equity percentage = $8,000 ÷ $18,000 = 44.4%. The maintenance requirement is 25%, and 44.4% > 25%, so NO margin call is required. A margin call would trigger if equity fell to 25% of market value (market value would need to fall to about $13,333).
    Summary Recap & exam traps

    Chapter Essentials

    Account ownership decides where assets go when an owner dies: JTWROS passes a share directly to the surviving owners and bypasses probate, while TIC sends it to the deceased's estate. A custodial account (UGMA or UTMA) holds an irrevocable gift to a minor, with one custodian and one minor, no margin or options, and control passing to the minor at the age of majority. Discretion over what, how much, or whether to trade requires written authorization; choosing only the time or price of an order does not.

    On margin, Regulation T (set by the Federal Reserve) requires a 50% initial deposit, and equity = market value − debit balance. After that, FINRA maintenance is 25% for long positions and 30% for short positions, with most firms setting stricter house requirements; fall below it and the firm can issue a margin call and sell securities without notice. Options, mutual funds and new issues (first 30 days), and penny stocks cannot be bought on margin, and it takes $2,000 of equity to open a margin account.

    Exam Traps to Watch

    The reliable gotchas in this chapter:

    JTWROS goes to the survivor, TIC goes to the estate. That single distinction is the most tested point on account registration. JTWROS bypasses probate; TIC can have unequal ownership shares.

    Time and price are not discretion. A broker who picks only when or at what price to fill an order the customer already specified is not exercising discretion. Choosing the security, the amount, or whether to buy or sell is, and that needs written authorization.

    Reg T is 50% and set by the Fed; maintenance is FINRA's. Do not mix them. Regulation T (Federal Reserve) is the 50% initial deposit; FINRA maintenance is 25% long and 30% short, with house requirements often higher.

    The loan does not shrink. When a margin stock falls, the debit balance stays fixed and equity absorbs the whole drop, which is what eventually triggers a maintenance call.

    Some things can't be bought on margin. Options, mutual funds and new issues for their first 30 days, and penny stocks must be paid in full, and it takes $2,000 of equity to open a margin account.

    Custodial accounts are irrevocable and bare-bones. One custodian, one minor, the gift cannot be reclaimed, and no margin or options. Control transfers to the minor at the age of majority.
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