OPRA Exam common mistakes
OPRA Exam · Understand the traps and how to avoid them.
When a scenario pits a high-level principle (acting honestly, fairly and professionally; treating customers fairly) against a specific technical rule, the candidate answers that the firm may follow the technical rule and treat the principle as aspirational, or that commercial pressure justifies a departure.
Revision tends to be done from rule lists and checklists, so principles and outcome-based obligations get skimmed as 'background' rather than as enforceable obligations that sit above the detailed rules.
What to do instead
For every scenario, run the obligations in order: principle/outcome first, then the specific rule, then the firm's own policy. If the specific rule appears to permit conduct the principle would not, the principle wins and the answer should describe the restriction or escalation, not the loophole.
The candidate spots only direct, personal financial conflicts (own shares, own commission) and misses indirect ones - a spouse's holding in the counterparty, a previous employer, a group company that will earn from the transaction, or a colleague's outside interest - then treats disclosure to the client as a complete remedy and lets the transaction proceed.
Conflicts training is often remembered as a gifts-and-inducements topic, and 'disclose' is the easiest remedy to recall, so it becomes a default answer for every conflict scenario.
What to do instead
Screen for conflicts against connected persons and the firm/group, not just the individual's pocket. Then apply the hierarchy in order: avoid or decline the business; if that is not possible, manage with controls (Chinese walls, separate supervision, removal from the decision); disclose only where management is genuinely effective, and record the decision.
The candidate answers a client-classification question using the protections that feel proportionate to the client's apparent sophistication (for example applying retail conduct and disclosure protections to an elective professional, or full retail protections to an eligible counterparty) instead of the protections that attach to the documented category.
Scenarios are written to make the client sound knowledgeable, which pulls the candidate toward a substance-over-form answer, whereas the applicable rule set in most regimes turns on the category the firm has actually assigned and documented.
What to do instead
Ask two questions before answering: what category is this client documented as, and does the rule in the question apply to that category? Confirm the opt-up was properly given, warned about and recorded, and check whether the rule applies to the firm acting for that client at all.
The candidate treats suitability as a single event completed at onboarding, so a scenario involving a later recommendation, a change in the client's circumstances, or a product outside the original mandate is answered by referring back to the original onboarding file as if it were still valid.
The topic is taught alongside onboarding and account documentation, which frames suitability as a form-filling exercise rather than a live obligation attaching to each recommendation and each periodic review.
What to do instead
Attach suitability to the act, not the account: for each recommendation or discretionary decision, identify the information gathered, whether it is current, whether the product sits inside the agreed mandate and risk profile, and what triggers a refresh (change of circumstances, review cycle, product risk change). Say explicitly that onboarding satisfies the initial test only.
In order-handling scenarios the candidate equates best execution with obtaining the best price, and accepts delaying or re-pricing a client order because the firm's own or another client's order has better economics, or because a cheaper venue or a faster route is available.
'Best execution' is remembered as a price test, and proprietary trading and order allocation are treated as commercial matters outside the conduct rules.
What to do instead
State the execution factors explicitly - price, cost, speed, likelihood of execution and settlement, size and nature of the order - and show that the firm's execution policy was applied and monitored. On priority, apply client orders ahead of the firm's own and adhere to the firm's order-handling and allocation policy, which must be designed to prevent client detriment.
The candidate uses trade date and settlement date interchangeably when describing obligations, controls and risk - for example saying settlement risk begins at execution, or that the client's obligation to pay arises only on settlement date.
Both dates appear in the same workflow and the difference is easy to collapse under time pressure, especially when the question only says 'the transaction'.
What to do instead
Lay the timeline out before answering: execution and trade capture and confirmation/affirmation, then clearing, then settlement. Attach each question to the correct point - trade-date reporting and confirmation, settlement-date money and securities movement - and use the standard settlement cycle defined in the scenario.
Faced with a reconciliation break, the candidate chooses the option that clears the difference through a suspense or adjustment entry, or writes it off below a tolerance, so the accounts balance, without identifying the cause, the owner or the ageing of the item.
Reconciliation is remembered as an arithmetic control ('do the two sides agree?') rather than as an investigation and escalation control, and clearing the break feels like resolving it.
What to do instead
Treat every break as an open item needing a root cause, an assigned owner, an ageing record and escalation beyond a defined threshold. Any manual adjustment must be approved, documented and auditable, and the underlying cause must be fixed - a plug that makes the number agree is a control failure, not a control.
The candidate assumes that because the firm's systems capture trades and emails electronically, records are automatically compliant, and does not consider retention periods, immutability and audit trails, recovery in the event of system failure, or business communications sent through unapproved channels on personal devices.
Records questions look like IT questions, so the candidate answers 'the system does it' rather than testing the record's completeness, integrity, retrievability and retention against the applicable requirement.
What to do instead
Check four things for any record: is it complete and captured at source, can it be retrieved promptly in the required format, is it retained for the required period and protected from alteration, and does it cover off-system channels. For off-channel communications, the compliant answer is capture, supervision or prohibition - not 'it is only a personal phone'.
The candidate decides whether a transaction is suspicious by reference to its size or whether it exceeds a reporting threshold, and in the same scenario tells the client, colleague or counterparty that a report is being or may be made in order to be transparent.
Thresholds are memorable and quantitative, and 'be open with the client' is a strong default conduct instinct, so the tipping-off prohibition gets overridden by a fairness reflex.
What to do instead
Suspicion is a qualitative judgement - it can arise from a small transaction with no economic rationale, unusual structuring, a mismatch with the client profile or adverse information. Report internally to the nominated officer/MLRO, let that person decide whether an external report is made, and do not disclose to the client or any third party that a report has been or may be made.
When a client expresses dissatisfaction, the candidate records it as service feedback, resolves it verbally and closes the file, or handles it informally to avoid creating a formal complaint record and the associated timeline.
Most dissatisfaction in practice is resolved quickly and amicably, so the candidate optimises for the client relationship and forgets that the definition of a complaint turns on the client's expression of dissatisfaction, not on the firm's view of whether it is justified.
What to do instead
Log at the point dissatisfaction is expressed, regardless of whether it is justified or is resolved the same day. Then apply the formal process: acknowledgement, the prescribed resolution timeline and any holding response, the client's right to escalate to the ombudsman or regulator, root-cause analysis and reporting of complaint data.