FINRA and SEC investor guidance separates a trusted contact from a person authorised to transact. Brokerage account roles need distinct permissions.

What the source establishes

The joint FINRA and SEC investor bulletin describes a trusted contact as someone a brokerage may contact in limited circumstances, including difficulty reaching the customer or concern about possible financial exploitation. The person must be at least 18. Providing a trusted contact is not mandatory to open an account. FINRA and SEC investor bulletin — trusted contacts ↗

The guidance expressly says that designation does not confer authority to act for the customer, execute transactions or engage in account activity. It is therefore a different role from a legal representative or an authorised trader. FINRA and SEC investor bulletin — trusted contacts ↗

What the distinction changes

For an operations team, storing these people under one generic contact type can create a permissions problem. An employee may see a familiar name and assume the person can give instructions, even though the recorded designation only permits limited contact.

WFN’s process analysis is to preserve the reason for the relationship alongside the contact details. Information disclosure, account access and transaction authority should each map to their own basis. A successful identity check establishes who answered, not what that person may authorise.

Questions for the next review

Review account-role labels and escalation procedures against the firm’s disclosures and applicable requirements. Check that staff can distinguish a trusted contact, beneficiary and power-of-attorney holder. Do not infer authority from an emergency-contact field or from a shared surname.