FINRA Rule 3250

The substance has never changed through any iteration: accounts must be maintained in the customer's true name, with the numbered account exception available only where a signed written ownership attestation is on file.

The Account Ownership Transparency Principle

The foundational investor protection principle implemented by Rule 3250 is that a broker-dealer's books must accurately reflect who owns each account.

This requirement matters because the customer account is the central unit around which virtually every regulatory obligation that a broker-dealer carries is organized. Suitability and Regulation Best Interest analysis, account statement delivery, tax reporting on Forms 1099, margin calls, transfer on death designations, regulatory examinations, fraud detection surveillance, and suspicious activity monitoring all operate at the account level. If an account is carried in a name that does not correspond to its actual beneficial owner, every one of these regulatory functions is simultaneously compromised.

The prohibition on carrying accounts in names other than the customer's forecloses two distinct fraud vectors that have appeared repeatedly in the enforcement record. The first is the scenario where a registered representative, firm employee, or third party maintains effective control over a customer's account while the account appears on the books in a fictitious or nominee name — concealing the actual controller's identity from the firm, from regulators, and from the customer whose assets are involved. The second is the inverse scenario, where an account is opened in a false name to conceal the beneficial owner's identity from the firm and from government authorities, facilitating tax evasion, sanctions evasion, or money laundering through what appears to be a legitimately designated securities account. Rule 3250's true-name requirement is the first-line defense against both patterns.

The Numbered Account Exception and Its Conditions

Rule 3250 provides a single narrow exception to the true-name requirement. A member may designate an account by a number or symbol rather than by the customer's name, provided the member has on file a written statement signed by the customer attesting ownership of that account. This accommodation serves legitimate privacy and confidentiality interests that some customers — particularly high-net-worth individuals, business executives, and certain international customers — have in not having their names appear across every level of internal account labeling in a broker-dealer's systems. The numbered designation is the securities industry's counterpart to the numbered account practices historically associated with private banking, limited in the domestic broker-dealer context to account labeling rather than extended to concealment of identity from the firm itself.

The conditions attached to the exception are precise and strictly construed. The written ownership attestation must exist before the numbered designation is used on the firm's books, must be signed by the customer personally, and must be maintained on file at the member for the life of the account and for the applicable retention period thereafter. The attestation is not a formality — it is the evidentiary record that ties the number or symbol appearing on the firm's books to a specific identified individual or legal entity whose identity has been verified through the firm's customer identification program. Without that signed written statement on file, the numbered account exception is unavailable and carrying the account without the customer's name on the books constitutes a direct Rule 3250 violation, regardless of the reason for the omission and regardless of whether the firm otherwise knows who the customer is.

The numbered account exception addresses only account labeling — how the account is identified on the firm's internal records and systems. It does not address, modify, or provide any relief from the identity verification and customer due diligence obligations that apply to every account under federal anti-money laundering law. A numbered account at a FINRA member firm must have a fully verified, documented owner whose identity has been confirmed through the customer identification program procedures required by 31 CFR 1023.220. The privacy benefit of the numbered designation is that the customer's name does not appear as the account label in the firm's general ledger and related systems; the regulatory requirement is that the customer's verified identity is unambiguously linked to that number in the firm's ownership attestation records.

Connection to Customer Identification Program Requirements

Rule 3250's prohibition on anonymous or fictitiously named accounts is the FINRA rulebook complement to the customer identification program requirements imposed on broker-dealers by the Bank Secrecy Act as amended by the USA PATRIOT Act of 2001. The CIP rule — codified at 31 CFR 1023.220 and adopted jointly by the SEC and FinCEN — requires broker-dealers to obtain and verify specified identifying information about each customer before opening an account, to maintain records of that information and the verification methods used, and to screen customer names against government lists of known or suspected terrorists and terrorist organizations maintained pursuant to Section 326 of the USA PATRIOT Act.

Rule 3250 and the CIP rule are operationally interdependent in the numbered account context. The CIP rule requires that customer identity be verified through documentary or non-documentary methods before the account is opened. Rule 3250 requires that the verified identity be linked to the numbered designation through the signed written attestation that must remain on file. Together they create a two-layer assurance: the customer has been identified and verified, and the numbered account on the firm's books is documented as belonging to that verified person. A firm that maintains a numbered account and satisfies Rule 3250's attestation requirement has not thereby satisfied the CIP rule — the attestation substitutes for the customer's name as the account label but does not substitute for the identity verification process. Both obligations must be independently satisfied.

FinCEN's Customer Due Diligence rule, effective May 11, 2018, added beneficial ownership verification requirements for legal entity customers — corporations, partnerships, trusts, and similar entities that open accounts in the entity's name rather than in the name of a natural person. The CDD rule requires broker-dealers to identify and verify the natural persons who own or control legal entity customers at account opening and to maintain procedures for ongoing monitoring of customer relationships. Rule 3250's requirement that accounts be carried in the customer's name is fully consistent with the beneficial ownership philosophy underlying the CDD rule — both rules are premised on the principle that accounts must be traceable to real, identifiable human beings or legal entities at every level of the account structure, and that the firm must have documented, verified ownership information that regulators can access during examinations and law enforcement can access during investigations.

Connection to FINRA Rule 3310 and AML Program Obligations

FINRA Rule 3310 — Anti-Money Laundering Compliance Program — requires every member to develop and implement a written AML program reasonably designed to comply with the Bank Secrecy Act and its implementing regulations. That program must include appropriate risk-based procedures for ongoing customer due diligence, understanding the nature and purpose of customer relationships, and monitoring for suspicious transactions. Rule 3250's account ownership transparency standard and Rule 3310's AML program requirements are mutually reinforcing: an account carried in violation of Rule 3250 — in a fictitious name, a nominee name, or a numbered format without the required attestation — is itself a potential indicator of suspicious activity that a properly functioning Rule 3310 AML program should detect and investigate.

Conversely, a firm's AML program must include procedures capable of identifying Rule 3250 deficiencies. Account opening procedures, new account review processes, and periodic account file audits should all include steps to verify that every account is carried in the customer's true name or, where a numbered designation exists, that a signed ownership attestation is on file and linked to a fully verified customer identity. The 2025 FINRA Annual Regulatory Oversight Report identified AML compliance — including customer identification and due diligence — as an ongoing examination priority, and firms whose account designation practices create gaps in the documented ownership chain will face findings under both Rule 3250 and Rule 3310 simultaneously.

Connection to Rule 4512 and Customer Account Information

Rule 3250 also connects directly to FINRA Rule 4512, which governs the customer account information that members must obtain and maintain. Rule 4512 requires members to make reasonable efforts to obtain specified information for each account at or prior to account opening, including the customer's name and residence — precisely the identifying information that Rule 3250 requires to appear on the firm's books as the account holder. The two rules operate in parallel at account opening: Rule 4512 drives the collection of the customer's identifying information, and Rule 3250 drives the requirement that collected identity be used as the account designation.

Where a customer requests a numbered account, both rules still apply in their full respective scope. Rule 4512 requires that the customer's name and other required identifying information be collected and maintained in the customer's account file regardless of whether a numbered designation is used. Rule 3250 requires that the signed ownership attestation linking the number to that identity be obtained and filed before the numbered designation is applied to the account. A firm that permits a numbered account while simultaneously failing to collect the customer name required by Rule 4512 has violated both rules and has created an account record that provides no reliable ownership documentation at any level — the most dangerous condition Rule 3250 was designed to prevent.

Supervisory Obligations and Written Procedures

Rule 3250's compliance obligations, while stated simply, require active supervisory implementation under FINRA Rule 3110. Written supervisory procedures must address account designation requirements, including the process for identifying whether a numbered or symbol designation has been applied to any account and verifying that a current signed ownership attestation is on file for each such account. Account opening procedures must include a step confirming that new accounts are opened in the customer's true name, or where a numbered designation is requested, that the written attestation is obtained and filed before the numbered designation is applied to the account on the firm's books.

Supervisory control testing under FINRA Rule 3120 should include periodic sampling of account records to confirm that the customer name appearing on the books corresponds to the verified customer identity maintained in the firm's CIP records, and that every numbered or symbol account has a current signed ownership attestation on file linked to that verified identity. Where accounts are transferred to a member firm from another broker-dealer, the receiving firm must ensure that Rule 3250's account ownership documentation standards are satisfied for all transferred accounts, including any numbered accounts, even where the transferring firm maintained its own ownership documentation — the obligation runs to the member carrying the account on its own books, not to the prior custodian.

The signed written ownership attestation required by Rule 3250's numbered account exception is a book and record of the member subject to the general preservation requirements of FINRA Rule 4511 and SEC Rule 17a-4. It must be preserved for the life of the account and for the applicable retention period after the account is closed — typically three years following account closure with the first two years in an easily accessible location, consistent with the general Exchange Act recordkeeping framework.

Examination Relevance and Key Takeaways

FINRA Rule 3250 is tested on the Series 7 General Securities Representative examination and the Series 24 General Securities Principal examination in the context of account administration requirements, customer identification obligations, and the foundational conduct rules governing how broker-dealers maintain their books and records. The rule appears most commonly in examination questions presenting a scenario involving a numbered or symbol account and asking whether the arrangement is permissible and under what specific conditions, or in questions connecting account designation practices to anti-money laundering and customer identification program requirements.

The key points to retain are these: FINRA Rule 3250 prohibits member firms from carrying any account on their books in the name of a person other than the actual customer — accounts must be maintained in the true name of their verified owner; a single exception permits accounts to be designated by a number or symbol rather than the customer's name, but only where the member has on file a written statement signed by the customer attesting ownership of that specific account; the written ownership attestation is a mandatory prerequisite to the numbered account exception and must be obtained before the numbered designation is applied.

The exception addresses only account labeling and does not relieve the firm of any obligation under the customer identification program requirements of 31 CFR 1023.220, FinCEN's Customer Due Diligence rule, or FINRA Rule 3310's anti-money laundering compliance program requirements; FINRA Rule 4512's customer account information requirements apply in full to numbered accounts and require the customer's name and other identifying information to be collected and maintained in the account file regardless of the numbered designation; the signed ownership attestation is a book and record of the member subject to the general preservation requirements of FINRA Rule 4511 and Exchange Act Rule 17a-4; and written supervisory procedures under FINRA Rule 3110 must address account designation compliance, including procedures for verifying that all numbered or symbol accounts have signed attestations on file linked to verified customer identities.