Review the customer-profile analysis that Series 22 uses to test DPP suitability and eligibility judgment.
Series 22 becomes more judgment-heavy once the account is open and the representative has to decide whether the customer actually belongs in the DPP. This is where profile quality, investor sophistication, and program-specific eligibility come together.
DPPs are often long-term, illiquid, complex, and tax-sensitive. That means the representative has to look beyond customer interest in yield or tax benefits and ask whether the investor can reasonably understand the structure and live with the risks. The exam usually rewards restraint here, not persuasion.
The stronger answer is normally the one that protects the customer from being matched with a program they cannot evaluate, fund, or hold. If the facts are weak, inconsistent, or incomplete, Series 22 usually favors gathering more information or declining the sale.
| Profile factor | Why it matters in a DPP recommendation | Weak exam instinct |
|---|---|---|
| liquidity needs | many DPPs are not easily sold or redeemed | assuming long-term interest means liquidity risk no longer matters |
| time horizon | the customer may need to hold through a long program life cycle | treating a short-term investor like a fit because projected cash flow looks attractive |
| income and net worth | the customer needs financial capacity to absorb uncertainty and illiquidity | focusing only on gross net worth without thinking about liquid resources |
| tax status | some programs are sold partly on tax features or tax-sensitive economics | treating tax interest as enough by itself to support the recommendation |
| experience and sophistication | the customer should be able to understand the structure and risks | confusing enthusiasm with actual understanding |
| concentration | a DPP can increase exposure to one issuer, sponsor, asset class, or strategy | ignoring the customer’s existing alternatives or illiquid holdings |
Series 22 often tests whether the representative can distinguish between:
Investor sophistication is about whether the customer can reasonably evaluate the program and its constraints. A person can be wealthy, interested, and still not understand the offering well enough to make a sound decision. The exam often rewards the answer that slows down the sale and explains the complexity instead of assuming the customer is fine because the account is large.
Many DPP offerings have program-specific purchaser standards, financial standards, or suitability representations. The representative should treat those as gating requirements, not as obstacles to talk around.
If the customer does not clearly meet the offering’s standards, the proper response is usually to:
The exam usually punishes attempts to “make the customer fit” after the profile already looks weak.
flowchart TD
A["Gather the customer's financial and investment profile"] --> B["Compare the profile to the DPP's risks, limits, and program standards"]
B --> C{"Is the customer both suitable and clearly eligible?"}
C -->|"No"| D["Obtain more information or decline the sale"]
C -->|"Yes"| E["Document the basis for the recommendation and proceed through supervision"]
When Series 22 gives you a customer who likes tax benefits, projected income, or sponsor prestige, ask the real screening questions:
If any of those answers are weak, the stronger response is usually not to recommend the DPP yet.
A customer with substantial net worth wants a DPP primarily for tax benefits. The representative learns that the customer may need access to a large portion of investable assets within two years and has little experience with illiquid programs. What is the strongest Series 22 response?
A. Recommend the DPP because the customer’s net worth is high B. Recommend the DPP if the sponsor is well known and the offering documents are delivered C. Delay the recommendation because liquidity needs and limited sophistication weaken the fit D. Proceed if the customer signs a statement acknowledging long-term risk
Answer: C. Series 22 usually favors the answer that recognizes illiquidity and complexity as real suitability barriers. A signed acknowledgment does not cure a weak profile match.