Review account-type selection and the disclosure obligations that accompany DPP account opening on Series 22.
The account-opening step for a direct participation program is really a control step. Series 22 is not asking whether the representative can mechanically open an account. It is asking whether the account form, ownership form, and opening disclosures all line up with an illiquid product that may tie up capital for years.
That matters because DPPs are not ordinary brokerage holdings. The customer may be purchasing a limited partnership, LLC interest, or similar participation interest with transfer restrictions, sponsor-driven economics, and program-specific eligibility standards. If the account form is wrong or the disclosures are incomplete, the later recommendation becomes harder to defend.
The stronger exam answer usually prefers the clearer and more restrictive opening approach. If a question makes you choose between moving quickly and making sure the legal owner, authority, and disclosure record are correct, Series 22 usually favors the documented approach.
Most Series 22 questions on account type are not about memorizing every retail account variation. They are about whether the representative recognizes:
If the legal owner on the new-account record does not match the subscriber or source-of-authority documents, the account-opening process is not complete yet.
| If the account is being opened for… | What the representative should verify | Common Series 22 trap |
|---|---|---|
| an individual customer | the legal name, tax identity, and risk/liquidity profile belong to the actual investor | assuming a simple individual account means fewer disclosures are needed |
| joint owners | the ownership form and required signatures match the customer intent and firm records | treating “joint account” as enough detail without checking the actual ownership structure |
| a trust, estate, or fiduciary account | the trustee or fiduciary has authority and the trust or estate documents support the purchase | accepting instructions from someone who is involved but not actually authorized |
| a corporation, partnership, or LLC | entity documents and signer authority support the subscription | matching the entity to the product without proving who can bind the entity |
| a retirement or custodial-style arrangement | the account structure and program terms are compatible and the custodian or fiduciary role is documented | assuming any long-term product automatically belongs in every tax-advantaged structure |
The account form is really the first piece of evidence showing who is buying the DPP. The exam often rewards the answer that slows down and fixes the ownership or authority issue before any recommendation is finalized.
Series 22 expects the representative to understand that the account-opening stage is also a disclosure-delivery stage. The customer should understand both the brokerage relationship and the broad nature of the DPP being discussed.
At this stage, the representative should make sure the customer receives or understands:
The exam often hides this behind a simple phrase like “open the account and proceed.” The better answer is usually the one that includes disclosure before acceptance rather than explanation after the sale.
flowchart TD
A["Identify the legal owner and intended account form"] --> B["Confirm authority, ownership, and compatibility with the DPP"]
B --> C["Deliver required relationship and product disclosures"]
C --> D{"Does the file clearly show the owner, authority, and disclosures?"}
D -->|"No"| E["Resolve the mismatch before moving forward"]
D -->|"Yes"| F["Continue to customer-profile and suitability review"]
If two answer choices both sound operationally possible, Series 22 usually prefers the one that:
The weaker answer is usually the one that assumes missing disclosure or ownership detail can be fixed later without affecting the recommendation.
A representative is opening an account for the purchase of a DPP interest. The customer says the investment is really for a family trust, but the new-account paperwork has been prepared as an individual account because the trustee is the person speaking with the representative. What is the best next step?
A. Open the individual account first and correct the ownership later if the subscription is accepted B. Use the individual account if the trustee verbally confirms the trust owns the assets C. Pause the process and verify the proper trust ownership and authority before proceeding D. Continue if the trustee has prior investing experience in illiquid products
Answer: C. Series 22 usually favors getting the legal owner and authority right before the DPP recommendation advances. Experience does not cure a mismatched account form.