Learn how Series 22 tests the collection and maintenance of customer facts, legal documents, and required account records.
Series 22 treats documentation as evidence, not paperwork for its own sake. The representative has to collect enough customer information and legal documentation for the firm to understand who the investor is, who can act, what the customer can tolerate, and whether the DPP subscription can survive principal review.
That is why missing or stale forms matter so much on this exam. An incomplete file is not just an operations problem. It can mean the recommendation is unsupported, the customer authority is unclear, or the firm has no defensible record of what was reviewed.
The strongest exam instinct is to ask a simple question: if a principal or regulator reviewed the file today, would the record clearly explain who bought the product, why it fit, and who had authority to sign? If not, the process is still incomplete.
The file should give the firm enough information to assess a DPP recommendation on real facts rather than assumptions. That usually includes:
Series 22 often tests this indirectly. The question may ask about a missing document, but what it is really testing is whether the representative recognizes that the firm lacks a reliable basis for approval.
| If the file needs to prove… | The representative should expect to see… | Why it matters on Series 22 |
|---|---|---|
| customer identity and profile | the account record and the firm’s core customer information | suitability and supervisory review cannot stand on guesswork |
| authority to invest | trust documents, entity authority, fiduciary authority, or equivalent legal support when applicable | the person signing must be able to bind the account |
| program suitability | profile information that supports illiquidity, risk tolerance, and financial capacity | DPPs are easy to oversell when the record is thin |
| subscription completeness | the current subscription package and required customer representations | incomplete subscriptions create both process and suitability risk |
| supervisory defensibility | a clean file showing what was collected and when | the firm must be able to reconstruct the decision path |
The exam often rewards the candidate who recognizes that different customers require different proof of authority.
The weak answer is usually the one that treats a signature as enough. Series 22 expects the representative to think about the legal capacity behind the signature.
If the file is outdated or incomplete, the problem is rarely limited to operations. It can mean:
On the exam, the better answer usually is to refresh or complete the record before the DPP sale moves ahead.
When a fact pattern mentions missing forms, outdated information, or incomplete legal support, the stronger response is usually to stop and repair the file rather than to “use reasonable judgment” and proceed. Series 22 generally rewards documented support, not improvisation.
A representative recommends a DPP to an LLC account. The managing member signs the subscription agreement, but the file does not contain any entity-authority document showing the signer can bind the LLC. What is the best next step?
A. Accept the subscription because the signer’s business title is probably enough B. Process the transaction if the representative has dealt with the signer before C. Obtain the legal authority documentation before the subscription is accepted D. Forward the file to the sponsor and let the sponsor decide whether authority is sufficient
Answer: C. Series 22 expects the representative and firm to verify authority in the account file. A familiar signer or plausible title is not a substitute for legal support.