Relationships and Dealings

Understand communications, vendor due diligence, and dealing standards with customers, vendors, and associated persons tested on Series 99.

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Series 99 expects the Operations Professional to understand that conduct risk exists in everyday dealings, not just in explicit fraud cases. Communications with customers, relationships with vendors, treatment of associated persons, and rules against paying commissions to unregistered persons all belong here because operations personnel often work across departments and with third parties.

The exam is usually testing whether the candidate recognizes a boundary. If the arrangement creates a conflict, involves an unregistered person improperly, or bypasses due diligence on a vendor or service provider, the operational relationship itself becomes the problem.

Key Takeaways

  • Everyday dealings can create conduct and supervision risk.
  • Vendor selection and third-party relationships require due diligence.
  • Operations professionals must recognize the boundaries around compensation and communications.
  • The exam often tests whether a relationship structure itself is inappropriate.

Sample Exam Question

Why would vendor due diligence appear on a Series 99 exam?

A. Because vendor relationships can affect operational integrity and customer protection
B. Because vendors may replace firm supervision entirely
C. Because only vendors may maintain books and records
D. Because all vendor payments are prohibited under FINRA rules

Answer: A. Series 99 includes vendor due diligence because third-party relationships can affect operations quality, data handling, and customer protection.

Revised on Thursday, April 23, 2026