Regulatory Alerts2003-10-01
Added
Question and Answer Regarding the Broker-Dealer Customer Identification Program Rule (31 CFR 103.122)
Broker-dealers are not required to treat beneficial owners as customers for omnibus or sub-accounts established by financial intermediaries when the intermediary initiates all transactions and holds control. Under 31 CFR 103.122, the financial intermediary is defined as the customer because it is the person identified as the accountholder. This guidance clarifies that broker-dealers do not need to look through the intermediary to the underlying beneficial owners in these specific circumstances.
Topics
Share