Regulatory Notice 10-18

FINRA Issues Guidance on Master and Sub-Account Arrangements

Executive Summary

FINRA reminds firms that maintain master/sub-account arrangements that, depending on the facts and circumstances of such arrangements, a firm may be required to recognize the sub-accounts as separate customer accounts for the purposes of applying FINRA rules, the federal securities laws and other applicable federal laws.


Questions concerning this Notice should be directed to:


  • Kris Dailey, Vice President, Risk Oversight & Operational Regulation, at (646) 315-8434;
  • Glen Garofalo, Director, Credit Regulation, at (646) 315-8464; or
  • Kathryn M. Moore, Assistant General Counsel, Office of General Counsel, at (202) 974-2974.