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Sample Questions
Question 1
Easy
A principal must ensure an ADF Trading Center is open for business, at minimum, from:
Solution
B is correct. FINRA Rule 6273 requires an ADF Trading Center to open by 9:30 a.m. Eastern Time and close no earlier than 4:00 p.m. Eastern Time. The principal must ensure coverage throughout that mandatory business period.
Question 2
Medium
Under FINRA Rule 5240, a principal supervising market makers must prohibit each of the following EXCEPT:
Solution
A is correct. FINRA Rule 5240 prohibits three kinds of conduct. A member may not coordinate quotations, prices or trades with another member. It may not direct or request another member to alter a price or quotation. It may not threaten, harass, coerce or intimidate another member to influence its quotes or trading. A market maker that independently decides to change its own bid in response to public market conditions, including a competitor's displayed quote, is engaged in ordinary competitive pricing. The rule does not reach that conduct, so the principal need not prohibit it.
Question 3
Hard
A new LLC's name clears the SDN list, but after funding, diligence shows two SDNs own 30% and 25% of it. What must the principal require?
Solution
A is correct. A clean name screen does not end the analysis, because OFAC's 50 Percent Rule treats an entity as blocked when one or more blocked persons own 50% or more of it, directly or indirectly, in the aggregate. The two SDN stakes are combined: 30% plus 25% equals 55%, so the LLC is blocked even though it is not listed and neither owner reaches 50% alone. The funds are now in the firm's possession and a blocked person has an interest in them, so the firm must block the property rather than return it. It must then report the blocked property to OFAC within 10 business days under 31 CFR 501.603(b)(1).
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