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Official Practice ProblemFINRA Series 7 Blueprint: Function 2
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Question #1115Function 2Fundamental

USA PATRIOT Act Customer Identification Program (CIP) Mandates

Under the USA PATRIOT Act Customer Identification Program (CIP), what 4 pieces of identifying information MUST a broker-dealer obtain from an individual customer BEFORE opening an account?

Correct Choice: A

CIP requires obtaining 4 mandatory items prior to opening an account: (1) Full Legal Name; (2) Date of Birth; (3) Physical Residential/Business Address (a P.O. Box is NOT acceptable without a residential/military address); and (4) Taxpayer Identification Number (SSN for U.S. citizens; passport/alien ID for foreign nationals).

Complete Analysis & Legal Rationale

Identity must then be verified within a reasonable time using documentary or non-documentary methods.

Distractor Autopsy (Why Other Options Are Traps)

FINRA exam writers design incorrect distractors using specific calculation mistakes and regulatory misconceptions. Review why each option succeeds or fails:

Choice ACorrect
Accurate CIP Law

Name, DOB, Physical Address, and Tax ID (SSN) are the statutory 4 CIP items.

Choice BIncorrect
Suitability vs CIP Confusion

Credit scores and net worth are suitability items, not the 4 mandatory CIP identity fields.

Choice CIncorrect
Irrelevant Background Items

References and salary are not CIP identity requirements.

Choice DIncorrect
Data vs Verification Document Confusion

Passports and licenses are verification documents, not the 4 core data points.

Regulatory Authority & Citations:
FinCEN31 CFR § 1023.220Customer Identification Programs for Broker-Dealers
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