1.1 Options Account Opening Requirements
Key Takeaways
- The Options Disclosure Document (ODD) must reach the customer at or before account approval, never after.
- A Registered Options Principal (ROP) or Senior ROP must approve every options account in writing before the first trade.
- The customer must return the signed options agreement within 15 calendar days of approval, or new opening transactions stop.
- FINRA Rule 2360 governs options account opening; verified financial and background data drive the approval decision.
- Trading levels must match the customer profile, and the approving principal documents that match.
Who Approves the Account
The Series 9/10 (General Securities Sales Supervisor) exam is a 90-minute, 55-scored-question test (plus 5 unscored pretest items) requiring a 70% passing score, and Chapter 1 leans heavily on FINRA Rule 2360 (Options). As a supervisor you act as a Registered Options Principal (ROP) or Senior Registered Options Principal (SROP). Every new options account must be approved in writing by a ROP or SROP before the first options order is accepted. The approving principal's signature and date are the proof that supervision occurred.
Exam trap: A general securities principal who is not options-qualified cannot approve an options account. Only a ROP/SROP can.
The Options Disclosure Document (ODD)
The Options Disclosure Document (ODD), formally titled Characteristics and Risks of Standardized Options and published by The Options Clearing Corporation (OCC), explains how options work and their risks. It is the single most testable opening-document timing rule.
| Question | Answer |
|---|---|
| When delivered? | At or before account approval |
| Who supplies it? | The OCC; the firm delivers it |
| Updates / supplements | Must be sent to existing customers when the OCC amends the ODD |
| Acceptable format | Paper or electronic (with consent) |
Exam trap: Delivery "at the first trade" or "within 15 days" is wrong. The 15-day clock belongs to the agreement, not the ODD.
The Options Agreement and the 15-Day Rule
After approval, the customer must sign and return the options agreement within 15 calendar days. The agreement is the customer's promise to abide by OCC rules and position/exercise limits.
- Day 0: account approved by ROP/SROP and first trade may occur.
- Within 15 calendar days: signed agreement must be returned.
- After day 15 with no agreement: no new opening transactions are permitted; the customer may only close existing positions.
The account is not closed and no penalty fee applies — the supervisor simply restricts the account to closing transactions until the form arrives.
Customer Information the Principal Must Verify
Before approval, the ROP gathers and verifies the customer's profile. Discrepancies must be resolved and documented.
| Category | Data required |
|---|---|
| Financial | Annual income, net worth, liquid net worth |
| Objectives | Income, growth, speculation, hedging, capital preservation |
| Experience | Prior options/securities trading, sophistication |
| Personal | Age, employment, marital status, dependents |
| Tax | Bracket and filing status |
Worked Approval Scenario
A representative submits an account for a 68-year-old retiree, annual income $40,000, net worth $300,000, objective "income," no prior options experience, requesting the highest level (uncovered call writing). The ROP should decline uncovered writing — naked call writing carries theoretically unlimited risk unsuitable for a low-income retiree with no experience — and instead approve a conservative level (covered calls), documenting the reasoning. Approving uncovered writing here is the classic exam wrong answer.
Tiered Trading Levels
| Level | Permitted strategies |
|---|---|
| 1 | Covered calls, protective puts |
| 2 | Long calls and long puts |
| 3 | Spreads (defined risk) |
| 4 | Uncovered (naked) put writing |
| 5 | Uncovered (naked) call writing |
Levels are firm-specific labels, but the principle is universal: the assigned level must align with the verified profile, and the principal owns that judgment. The risk ranking matters — an uncovered put has a large but finite maximum loss (strike minus premium), while an uncovered call has theoretically unlimited loss, which is why naked call writing sits at the highest level.
The SROP / ROP Distinction
Large firms designate a Senior Registered Options Principal (SROP) with overall compliance responsibility for the options program and a Compliance Registered Options Principal (CROP) focused on advertising and customer-complaint handling. Day-to-day account approvals can be delegated to any qualified ROP, but the SROP/CROP framework is what the exam expects you to name when asked who owns firm-wide options supervision. The Series 9 qualifies you to act in the sales-supervisor capacity; pairing it with the Series 10 General Securities Sales Supervisor module completes the principal-level authority over a branch's options business.
Documenting the Background and Financial Verification
FINRA Rule 2360 requires the firm to exercise due diligence to learn the essential facts about the customer before approval. The principal's file must show:
- The date the account was approved and by whom (signed/initialed).
- The specific trading level granted and the basis for it.
- Verification that the customer's stated income, net worth, and experience are internally consistent — a customer claiming $2 million net worth on $25,000 income is a discrepancy to resolve, not ignore.
- A record that the current ODD was delivered at or before approval.
Exam trap: The background/financial information must be verified within 15 calendar days of approval as well — the same 15-day window the agreement uses. If the customer never returns the verifying information, the firm is restricted to closing transactions, mirroring the agreement rule.
Common Opening-Stage Violations
| Violation | Why it fails |
|---|---|
| Trade accepted before ROP approval | Supervision must precede the first order |
| ODD delivered after the first trade | Disclosure must come at or before approval |
| Uncovered call writing granted to an inexperienced retiree | Profile does not support unlimited-risk strategies |
| Approval by a non-options principal | Only a ROP/SROP may approve |
| No re-delivery of an amended ODD | Existing customers must receive supplements |
The through-line for every opening question is sequence: gather and verify the profile, deliver the ODD, approve at the right level in writing, then accept orders — and chase the signed agreement within 15 days.
A customer's options account was approved on June 1. By June 20 the signed options agreement still has not been returned. What may the firm do?
Who is authorized to approve a new customer options account before the first options trade?