Financial Instruments and Exchange Commission Accounting Document "Customer Card"
Posted: May 2025, 4
Among the documents that financial instruments business operators must prepare, we will explain the "customer card."
Customer cards are important documents that are also checked during securities inspections.
We will also check this during our internal audits.
Despite this, there are many cases where these documents are not created/updated, or are not properly managed.
Take this opportunity to check how your company's customer cards are being used.
Why is a customer card necessary?
A customer card is a record of a customer's name, address, date of birth, etc.Accounting documents that record customer informationYou read it right!
Financial products business operators arePrinciple of suitability, etc. (Article 40 of the Financial Instruments and Exchange Act)Based on this, financial institutions are required to solicit financial products that are suitable for each customer using explanations and methods that are appropriate for each customer.
In order to "make product suggestions that are appropriate for that customer," it is necessary to understand the customer's attributes and other information in advance, and a "customer card" is necessary for this process of "obtaining → recording → saving customer information."
In other words, The "customer card" is a document required to comply with the principles of suitability, etc.What is it?
In practice, financial instruments business operators will go through the following steps:
① Obtain information about the customer in advance (name, date of birth, asset status, investment objectives, etc.)
② Record and store the acquired customer information on a customer card.
③ Based on the contents of the customer card, solicit financial products suited to the customer's investment intentions and investment decision-making ability
④ Update and share the contents of customer cards and manage them appropriately.
Please note that the customer card itself is not mandated by the Financial Instruments and Exchange Act, but its creation and storage are required by supervisory guidelines and the self-regulatory rules of various associations.
Customer card practices
[How to make]
Customer cards are basically created in one of the following ways (paper or electromagnetic record).
① Method in which the customer fills in or inputs the information themselves
② Method in which financial institutions prepare the documents by interviewing customers
In practice, it is common for the sales department staff who deal with customers to create the customer card (or check the information entered by the customer), and then the compliance department checks, verifies, and manages the information written on the card.
In services such as real estate trust beneficiary rights transactions, where the customer base is relatively older and contracts are concluded on paper, it seems that in many cases the customer is asked to fill out forms such as a "customer information sheet" or "intention confirmation sheet" themselves.
On the other hand, in the case of non-face-to-face transactions and platform services such as internet transactions, the information entered by the customer themselves is stored as their own My Page, and in some cases this My Page is operated as a customer card, allowing the customer to change it at any time and for financial institutions to view and edit it as well.
Depending on your company's customer base and service delivery methods, you should consider methods that impose as little burden as possible on both customers and financial institutions.
Regardless of the method used, you will essentially be obtaining information from the customer, but it is important not to simply accept what the customer self-reports, but to cross-reference it with other documents whenever possible and check for consistency with other information.
[Items to be described]
The following items should be included on the customer card:
Name, address, date of birth, contact information, occupation, investment purpose, asset status, investment experience and details, etc.
In reality, depending on the association you belong to,Separate provisions in self-regulation rulesPlease be careful as this may be the case.
For example, the Japan Securities Dealers AssociationSelf-regulatory rules ("Rules on investment solicitation, customer management, etc. by Association Members")The following are the items that should be included on the customer card (as of April 2025):
1. Name or title
2. Address or location and contact details
3. Date of birth (only if the customer is a natural person; the same applies in the next paragraph)
4. Occupation
5. Investment Objectives
6. Asset Status
7. Investment experience
8. Types of Transactions
9. Other matters that each Association Member deems necessary
[Storage method]
Customer cards can be stored not only on paper but alsoElectromagnetic records are also possible.
Please note that if you store accounting documents on electronic media, the supervision guidelines stipulate points to keep in mind.
(Comprehensive Guidelines for Supervision of Financial Instruments Business Operators, etc. > III-3-3 Books and Documents Related to Business > (6))
[Other (share/change)]
Customer cards are not something that are created and then finished. They should be shared with customers at the appropriate time, and customer information should be collected in a timely manner and updated as necessary.Appropriate customer information managementwill be required in addition to your identification documents.
Specifically, the supervisory guidelines andPublic commentIn this regard, the following actions are required:
・When creating the card: The investment objectives of the customer registered on the card are shared between the financial institution and the customer.
・When changing: If the customer's asset status, investment objectives, etc. change, change the customer's card after confirming with the customer.
・When making changes: The changed registration details must be shared between the financial instruments business operator and the customer.
Summary
That was about the customer card.
In addition, the principle of suitability (Article 40 of the Financial Instruments and Exchange Act) is exempt from application when the customer is a specified investor. Therefore, financial instruments business operators that conduct business exclusively for specified investors may be able to be more flexible in their customer card policies.
(However, it is dangerous to say, "Because this is limited to specified investors, there is no need to create a customer card.")
At Support Administrative Procedures Legal Professional Corporation, we provide practical support for financial instruments business operators, from creating customer cards (formats) suited to the characteristics of your business to auditing the status of their creation (internal audit support).
Not limited to customer cards,Support for internal management of financial instruments tradersIf you are interested, please contact us below.
Initial consultation is currently available free of charge.
Editor of this article
Sachiko Masuno
