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Series 7 > Types of Accounts > Flashcards

Types of Accounts Flashcards

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Series 7 Top-off Exam flashcards
1
Q

Two Most Common Accounts

A
  • Cash Account
  • Margin Account
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2
Q

Cash Accounts

A
  • (def) an account in which the customer is required by the Fed’s Reg T to pay, in full, for securities purchased no later than 2 days after the standard payment period set by the Uniform Practice Code
  • basic investment account & anyone is eligible to open an investment account can open a cash account
  • customer must pay in full for any securities purchased however there are some exceptions
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3
Q

Accounts That May ONLY Be Opened As Cash Accounts

A
  • Personal Retirement Accounts (IRAs)
  • Corporate Retirement Accounts (401Ks)
  • Custodial Accounts (Uniform Transfer to Minors Act accounts (UTMAs) & Coverdell Educations Savings Accounts (ESA))
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4
Q

Margin

A
  • (def) the amount of equity contributed by a customer as a percentage of the current market value of the securities held in a margin account
  • the term margin refers to the minimum amount of the equity a customer must deposit to buy securities
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5
Q

Fee-Based Accounts

A
  • Charge a single fee (either fixed or a percentage of assets in the account) instead of commission based charges
  • Are appropriate only for investors who engage in at least a moderate level of trading
  • Rules require that before opening a fee-based account, investors must be given a disclosure document
  • One benefit is they tend to reduce the likelihood of abusive sales practices (churning) however have introduced a new concept (reverse churning)
  • Are NOT wrap accounts
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6
Q

Churning

A

(def) excessive trading in a customer’s account with the view to generate commissions (syn - overtrading)

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7
Q

Reverse Churning

A

(def) the unsuitable practice of placing a client who trades infrequently in a fee-based account rather than a commission-based account that would be more appropriate

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8
Q

Wrap Accounts

A
  • Account for which firms provide a group of advisory services in addition to brokerage services
  • Advisory services might include asset allocation, portfolio management, executions & administration
  • Account is charged a single fee (usually a percentage of assets being managed)
  • Firms offering wrap account are generally required to register as investment advisors in addition to their registration as a broker dealer
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9
Q

Prime Brokerage Account

A
  • A customer (generally an institution - Think Financial Planning) selects one member firm (the prime broker) to provide custody, trading and other services, while other firms, called EXECUTING BROKERS, typically execute most the trades placed by the customer
  • Key advantage is it usually provides a client with the ability to trade with multiple brokerage houses while maintaining a centralized master account with all of the client’s cash & securities
  • Often includes a list of specialized services, such as securities lending, margin financing, trade processing, cash management an operational support
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10
Q

Broker

A
  • (def 1) an individual or firm that charges a fee or commission for executing buy and sell orders submitted by a customer
  • (def 2) the role of a firm when it acts as an agent for a customer and charges the customer a commission for its services
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11
Q

Trusted Contact Person (Rules 2165 & 4512)

A
  • There is a requirement to obtain trusted contact info for SPECIFIED ADULTS
  • FINRA requires members to make reasonable efforts to obtain the name of and contact info for a trusted contact person
  • The rules do not require a customer to provide trusted contact info, ONLY that the firm make the effort
  • Member firms may place a temporary hold on the distribution of funds or securities from the account of a specified adult WHEN they believe that financial exploitation of the specified adult has occurred, is occurring, has been attempted, or will be attempted
    FINRA considers TEMPORARY to be up to 15 business days
    This rule does not require members to place a temporary hold, the rule SIMPLY gives them permission to do so
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12
Q

Specified Adult

A
  • A natural person age 65 or older or a natural person age 18 or older who the member reasonably believes has a mental or physical impairment that makes the individual unable to protect his own interests
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13
Q

Regulation S-P (Privacy Notices)

A
  • Opening an account usually requires complying with Regulation S-P
  • Enacted by the SEC to protect the privacy of customer info (nonpublic personal info)
  • Firm must provide a privacy notice describing its privacy policies to customers whenever a new account is opened and annually thereafter
  • If firm reserves the right to disclose to unaffiliated third parties nonpublic personal info, the notice must provide customers a reasonable means to opt out of this disclosure
    -The reg embodies the obligation of financials to safeguard customer info as related to all forms of existing and developing technology
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14
Q

Regulation S-P
Consumer vs Customer

A
  • CONSUMER is an individual who obtains a financial product or service from a firm and has no further contact with the firm; are given an initial privacy notice only
  • CUSTOMER is an individual who has an ongoing relationship with a firm; must be given both an initial and annual privacy notice
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15
Q

Power of Attorney (POA)

A
  • If a person who is not named on an account is to have trading authority, the customer must file written authorization with the BD giving that persona access to the account
  • Trading authorization usually takes the form of a POA; two basic types: full POA and limited POA
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16
Q

Full POA

A
  • Allows an individual who is not the owner of an account to: 1) deposit or withdraw cash or securities and 2) make investment decisions for the account owner
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17
Q

Limited POA

A
  • Allows an individual to have some, but not total, control over an account
  • The doc specifies the level of access the person may excercise
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18
Q

Durable POA

A
  • Full or limited POA may be made “durable” by the grantor of the power
  • Durable specifically designates a POA to maintain power over the account even upon the grantor’s incapacitation - mental or physical
  • Death of the principal, ceases all forms of POA
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19
Q

Approval & Documentation of Changes in Account Name or Designation

A
  • Under FINRA rules, no change in any account name(s) can be made unless the change has been authorized by a qualified registered principal designated by the member (ie - divorce pending and one spouse tries to remove another)
  • Principal must be personally informed of the essential facts relative thereto and indicate her approval of such change in writing
  • Must be documented in writing & preserved with the customer account records
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20
Q

Internal Transfers

A
  • It is not unusual for a client to have both a cash account and a margin account
  • When a transfer is made to an account form an account of which the recipient is not a signatory, approvals and documentation similar to a change in designation are required (ie - joint account transfer to an individual account)
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21
Q

Bulk Transfers

A
  • When customers sell securities held in their accounts, cash representing the proceeds of those sales are deposited to their accounts
  • That cash is swept into a MM mutual fund where it will earn income until the money is either w/drawn or used for a new purchase - known as a SWEEP ACCOUNT
  • Contacting each of the clients individually to receive their consent is not practical
  • FINRA rules do permit member firms to make bulk exchanges at net asset value (NAV) of MM mutual funds utilizing negative response letters w/o obtaining affirmative consent, but only when specific conditions are met
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22
Q

Negative Response Letter

A
  • Generally informs the recipient of the letter of a impending action & requires the recipient to respond or act w/in a specified time frame if the recipient objects to the action
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23
Q

Negative Response Letter Conditions for Bulk Transfers

A
  • The bulk exchange is limited to situations involving mergers & acquisitions of funds, changes of clearing members & exchanges of funds used in sweep accounts
  • The negative response letter contains a tabular comparison of the nature & amount of the fees charged by each fund
  • The negative response letter contains a comparative description of the investment objectives of each fund & a prospectus of the fund to be purchased
  • The negative response feature will not be activated until at least 30 days after the letter was mailed
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24
Q

Tax-Deferred

A
  • Income tax is put off to a later time
  • In most retirement plans, tax on the amount of the contribution is usually deferred until withdrawal
  • Tax on the earnings is always deferred until withdrawal
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25
Q

Qualified Plan

A
  • An employer-sponsored plan (pension, 401(k) or 403(b)) where the contributions are made with pretax dollars & earnings in the account grow w/o any tax (tax deferred) until the funds are withdrawn
  • Are usually governed by the Employee Retirement Income Security Act of 1974
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26
Q

ERISA

A

Employee Retirement Income Security Act of 1974

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27
Q

Qualified

A
  • Term by itself means that contributions made with pretax dollars & earnings in the account are tax-deferred until the funds are withdrawn
  • Can apply to either a qualified plan or a traditional IRA
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28
Q

Nonqualified

A
  • An employer-sponsored plan where there are no tax advantages other than that the pay is not received until sometime later when the individual should be in a lower tax bracket
  • Another advantage is that the employer can discriminate between employees
  • Term can also apply to an annuity purchased on an individual basis outside of a retirement plan
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29
Q

Deductible Contribution

A
  • Contribution made by the individual, whether an employee contribution to a qualified plan (401k) or by any individual to a traditional IRA
  • Means the amount contributed is pretax or otherwise deductible on the tax return
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30
Q

Nondeductible Contribution

A
  • Contribution to a qualified plan or an IRA (traditional or Roth) which is made with after-tax dollars
  • The funds do grow tax-deferred but there is no tax benefit derived from the contribution
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31
Q

Employer-Sponsored Retirement Plans

A
  • Two basic types of retirement plans in the US: qualified & nonqualified
  • Qualified plans allow pretax contributions to be made while nonqualified plans are funded with after-tax money
  • Both plans can allow money to grow tax-deferred until needed
  • Contribution limits for qualified retirement plans vary & are adjusted from time to time
  • A taxable distribution from any retirement plan is taxed as ordinary income, never as capital gains
  • In a qualified plan, if all funds were contributed by the employer or if the employee’s contributions were pre-taxed, the tax basis (cost) is zero - because everything above the cost is taxed at the employee’s ordinary income rate at the time of distribution, in most cases all funds received are fully taxable
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32
Q

Nonqualified Plans

A
  • May be used to favor certain employees (ie - executives) b/c nondiscrimination rules are not applicable
  • These do not have to comply with ERISA
33
Q

Deferred Compensation Plan

A
  • A nonqualified deferred compensation plan is an agreement b/t a company and an employee in which the employee agrees to defer receipt of current income in favor of payout at retirement
  • May be somewhat risky b/c the employee covered by the plan has no right to plan benefits if the biz fails - employee becomes a general creditor of the firm
    -Covered employees may also forfeit benefits if they leave the firm before retirement
  • When the benefit is payable at the employee’s retirement, it is taxable as ordinary income to the employee; the employer is entitled to the tax deduction at the time the benefit is paid out
  • Usually benefit highly compensated employees who are just a few years from retirement
34
Q

Payroll Deduction Plan

A
  • Allow employees to authorize their employer to deduct a specified amount for retirement savings from their paychecks
  • The money is deducted after taxes are paid & may be invested in any number of retirement vehicles at th employee’s option
35
Q

Qualified Plans

A
  • Most offer several specific tax benefits differing from those in nonqualified ones; BENEFITS:
  • Employer contributions are a current deductible expense
  • Employee contributions are generally made with pretax money
  • All earnings & growth in the account is tax-deferred until withdrawal and
  • Certain protections are offered to employees under ERISA
36
Q

Individual Retirement Accounts (IRAs)

A
  • Were created to encourage people to save for their retirement
  • Any individual with earned income can open & contribute to an IRA
  • Two types: Traditional IRAs and Roth IRAs
37
Q

Traditional IRAs

A
  • Was the first IRA (really is just referred to as IRA)
  • Allows a maximum TAX-DEDUCTIBLE annual contribution of the lesser of $6,000 per individual or $12,000 per couple or 100% of taxable compensation for the taxable year 2019
  • Income & capital games earned in the account are tax-deferred until the funds are w/drawn
38
Q

Compensation for IRA Purposes

A
  • Wages, salaries & tips
  • Commissions & bonuses
  • Self employment income
  • Alimony (starting 01/2019 - alimony is no longer earned income)
  • Nontaxable combat pay
39
Q

Not Compensation for IRA Purposes

A
  • Capital gains
  • Interest & dividend income
  • Pension 0r annuity income
  • Child support
  • Passive income from DPPs
40
Q

Catch-Up Contributions for Older IRA Owners

A
  • Economic Growth & Tax Relief Reconciliation Act of 2001 (EGTRRA) was the source of the legislation permitting certain individuals to make additional contributions to their IRAs
  • Individuals aged 50 & older
  • These can go either to an IRA or to a Roth IRA
  • Since 2006, the catch-up amount has been $1,000
41
Q

Who Can Contribute to an IRA

A
  • Any taxpayer of any age who reports earned income for a given tax year may contribute
  • If one spouse has little or no earned income & a joint tax return is filed, a spousal IRA may be opened to that person & the contribution limits & tax treatment are the same as for any other IRA
42
Q

Earnings Limitations for Tax Benefits

A
  • Traditional participants may deduct contributions to their IRAs from their taxable income
  • The deductibility limits are reduced or even eliminated for individuals who are covered by employer-sponsored qualified plans
  • Individuals wo do not participate in qualified plans may deduct IRA contributions regardless of income level
  • Limits are higher if only one of the spouses participates in a qualified plans
  • Limits only deal with the deductibility of contributions - full contributions can still be made- just part or none of it can be deducted based on income levels
43
Q

Time for Contributions

A
  • Ira contributions for a specific taxable year may be made anytime from Jan 1 of that year through the required filing date of that year’s return (April 15th of the following year) - regardless of extension
44
Q

Excess Contributions

A
  • Annual IRA contributions exceeding the maximum allowed are subject to a 6% penalty tax if the excess is not removed by the time the taxpayer files their taxes
45
Q

Roth IRAs

A
  • Created as part of the Taxpayer Relief Act of 1997
  • Contributions are NOT tax deductible
  • Earning are not merely tax-deferred; they can be tax-free
46
Q

Roth IRA Earnings Accumulated May Be Withdrawn Tax-Free, 5 Years Following the Initial Deposit Provided The

A
  • Account holder is 59 1/2 or older
  • Money withdrawn is used for the first-time purchase of a principal residence (up to $10,000) OR
  • Account holder has died or becomes disabled
  • Regular contributions may always be withdrawn tax-free b/c they are made with nondeductible contributions
47
Q

Contribution Limits to Roth IRAs

A
  • Are the same as those for IRAs
  • No age limitations as long as the taxpayer has earned income
  • Any individual may contribute to both an IRA an d a Roth IRA - the max combined contributions is $6,000 ($7,000 if 50+ yrs)
48
Q

Eligibility Requirements for Roth IRAs

A
  • Are limits placed on Roth IRA eligibility based on income
  • Anyone with earned income is eligible to open a Roth IRA provided the person’s AGI falls below specified income levels
49
Q

AGI

A

Adjusted Gross Income

50
Q

Adjusted Gross Income (definition)

A
  • AGI
  • Gross income from all sources minus certain adjustments to income, such as deductible contributions to an IRA & net capital losses
  • It is the amount of income that will be subject to tax
51
Q

Adjusted Gross Income (AGI)

A
  • Is computed on the bottom of the first page of your Form 1040, listing all your earned income minus certain items
  • Deductible items: IRA contributions, alimony paid as part of a pre-Jan 2019 divorce decree, self employment tax AND penalties paid on early withdrawal from a savings account
52
Q

Roth Conversions

A
  • Anyone with an IRA is permitted to convert it to a Roth IRA
  • There are income tax consequences
  • The entire amount converted is added to the investor’s ordinary income
  • If direct rollover or transfer from trustee to trustee or rollover w/in 60 days, there will be no 10% early distributions tax penalty for those under 59 1/2
  • If contributions to IRA were made with after-tax money, the IRS uses a proportionate system to determine how much is nontaxable
53
Q

Key Points to Remember About the Roth IRA

A
  • Contributions are not tax deductible
  • Distributions are tax-free if taken after age 59 1/2 & a Roth account has been open for at least 5 years
  • Contributions can be made at any age as long as there is earned income
  • Distributions are not required to begin at age 72
  • If b/c of death, disability or first-time home purchase, the distribution is qualified & not subject to tax or the 10% penalty
  • As with all IRAs, there must be a named beneficiary (who can be a minor)
  • Contributions (all made with after-tax money) may always be withdrawn without tax or penalty. It is only the earnings where the 5 years/age 59 1/2 rules apply to avoid tax & penalties
54
Q

Withdrawals From Traditional IRAs

A
  • Distributions without penalty may begin after age 59 1/2 & MUST begin by April 1 of the year following the year an individual turns 72
  • Distributions before age 59 1/2 may be subject to a tax penalty & withdrawals less than the required minimum distributions (RMDs), after age 72 may also incur tax penalties
  • To the extent withdrawals are from tax-deductible contributions, they are taxable as ordinary income
55
Q

Taxable Withdrawals Before Age 59 1/2 Are Also Subject To A 10% Early Withdrawal Penalty Unless They Are Because Of

A
  • Death
  • Disability
  • First time purchase of a primary residence ($10,000 lifetime max)
  • Qualified higher education expenses for immediate family members (including grandchildren) OR
  • Certain medical expenses in excess of an AGI limit
56
Q

Required Minimum Distributions (RMDs)

A
  • Withdrawals must begin by April 1 of the year following the year in which the account owner reaches age 72
  • They must meet minimum INTERNAL REVENUE CODE (IRC) distribution requirements or incur 50% penalty on the amounts falling short of the RMD
  • There are no RMDs & the account will continue to grow tax-free until the holder decides to take it out on Roth IRAs
57
Q

Nondeductible Capital Withdrawals

A
  • IRA investors who contribute after-tax dollars to an IRA are not taxed on those funds when they are withdrawn from the account but taxpayers are taxed at the ordinary income tax rate when they withdraw funds resulting from investment gains or income
58
Q

IRA Investments

A
  • Fund in an IRA account may be used to buy stocks, bonds, mutual funds, UITs, limited partnerships, REITS, US government securities & gold or silver coins minted by the US Treasury Dept (American Eagles) as well as certain platinum coins & certain gold, silver & platinum bullion, annuities & many other investments
  • Should be relatively conservative & should reflect the investor’s age & risk tolerance profile
  • Manger for adequate long-term growth
59
Q

Ineligible & In appropriate IRA Investments

A
  • Collectible, including antiques, gems, rare coins, works of art & stamps
  • Life insurance contracts (such as whole life & term)
  • Tax free municipal bonds, municipal bond funds & municipal bond UITs are eligible but generally considered inappropriate (yields are typically lower & income generated is taxable on withdrawal)
60
Q

Ineligible Investment Practices

A
  • No margin account trading, including short sales
  • No speculative options strategies such as uncovered (naked) puts & calls
  • Covered call writing & buying puts & calls is allowed
61
Q

Moving IRAs

A
  • 60 Day Rollover
  • Direct Rollover
  • Trustee to trustee transfer
62
Q

60-Day Rollover

A
  • IRA owner may take temporary possession of the account funds to move the retirement account to another custodian
  • Only ONCE per 12-month period
  • Must be completed w/in 60 calendar days of the funds withdrawal from the original plan
  • 100% of the withdrawn amount must be rolled into the new account
63
Q

60-Day Rollover of Employer-Sponsored Qualified Plan

A
  • May move their plan assets to a rollover IRA if they leave the company & elects to take a lump-sum distribution
  • Must complete the rollover w/in 60 calendar days of withdrawing the funds from the qualified plan
  • When the participant takes possession of the funds to make it a rollover, the payor of the distribution MUST, by law, withhold 20% of the distribution as a withholding tax
  • The participant MUST, nonetheless, roll over 100% of the plan distribution, INCLUDING the funds withheld, or be subject to income tax & if applicable, an early withdrawal penalty
64
Q

Direct Rollovers From Retirement Plans to IRAs

A
  • A distribution from an employer-sponsored retirement plan to an IRA, either traditional or Roth
  • The key to a direct rollover is that the money is never seen by the employee & moves directly from the current plan administrator to another administrator
65
Q

Trustee to Trustee Transfers

A
  • Simply referred to as an IRA transfer
  • Are when account assets are sent directly from one IRA custodian to another and the account owner never takes possession of the funds
  • Number of IRA transfers an account owner may make per is year is unlimited
  • Direct rollovers & transfers generally make better sense than 60-day rollovers b/c the 20% Federal tax withholding does not apply AND no specified time limit
66
Q

Education IRA

A
  • Taxpayer Relief Act of 1997 created with a $500 annual contribution limit
  • In 2002, renamed to COVERDELL ESAs and the annual contribution limit is now $2,000
  • Allow after-tax contributions for student beneficiaries
  • Contributions must be made in cash & must be made on or before the date on which the beneficiary attains age 18 (unless special needs)
  • Fund educational expenses of a designated beneficiary by allowing after-tax (nondeductible) contributions to accumulate on a tax-deferred basis
  • When distributions are made, the earning portion of the distribution is excluded from income when it is used to pay qualified education expenses
  • Non qualified expenses are subject to 10% penalty and withdrawn earnings are taxed to the recipient (beneficiary)
  • Can be used for elementary, high school, college - public, private or religious
  • Contribution to a Coverdell ESA may be limited depending on the amount of AGI & filing status
  • Provisions that allow contributions to continue past age 18 for Benes with special needs
  • Contributions, for any year, to be made up to April 15 of the following year (like IRAs)
67
Q

Key Points about Coverdell ESAs

A
  • Contributions can be made by parents & other adults; the total for one child is still $2,000
  • Contribution limit is $2,000 per year per child until the child’s 18th birthday
  • Contributions are not tax deductible, but all earnings are tax-deferred
  • Distributions are tax-free if they are taken BEFORE age 30 & used for eligible education expenses
  • If the accumulated value in the account is not used by age 30 , the must be distributed & subject to income tax & a 10% penalty on the earnings or rolled over into a different Coverdell ESA for another family member
68
Q

Tax-Sheltered Annuities (403b Plans)

A
  • Most common plan for those employed by the public school system
  • Also available to many nonprofit orgs operating under section 501c3 & religious orgs
  • Qualified employees may exclude contributions from their taxable incomes provided they do not exceed limits
  • Intended to encourage retirement savings, therefore these plans are subject to tax penalties if savings are withdrawn before a participant reaches age 59 1/2
  • Eligible if at least 21 years old & have completed 1 year of service
  • Funded by elective employee deferrals
  • The deferred amount is excluded from the employee’s gross income & earnings accumulate tax-free until distribution
  • A written salary reduction agreement must be executed b/t the employer & the employee
  • Employer can make contributions solely on behalf of the covered employee or in conjunction with an employee deferral
  • Distributions are 100% taxable & a 10% penalty is applied to distributions before age 59 1/2
69
Q

Tax Advantages of 403b Plans (TSAs)

A
  • Contributions (which generally come from salary reduction) are excluded from a participant’s gross income
  • Participants’ earnings accumulate tax-free until distribution
70
Q

TSA

A

Tax-Sheltered Annuity

71
Q

TSA/403b Plan Investments

A
  • Historically these plans were (and still are) referred to as TSAs b/c annuities were the only investment option
  • In 1974 a provision was made to permit the purchase of mutual funds, although it is estimated that more than 85% of all 403b money is invested in either fixed or variable annuities
72
Q

Section 457 Plans

A
  • A deferred compensation plan set under Section 457 of the tax code that may be used by employees of a state, political subdivision of a state & any agency or instrumentality of a state
  • Technically a nonqualified plan, employees can defer compensation in a 457 plan & the amount deferred is not reportable for tax purposes, therefore the employee receives a deduction each year for the amount deferred
73
Q

Important Facts About 457 Plans

A
  • Plans are exempt from ERISA - nongovernmental plans must be unfunded to qualify for tax benefits while government plans must be funded
  • Plans are generally not required to follow the nondiscrimination rules of other retirement plans
  • Plans for tax-exempt organizations are limited to covering only highly compensated employees, while any employee (or even independent contractor) of a governmental entity may participate
  • Distributions from 457b plans of nongovernmental tax-exempt employees may not be rolled over into an IRA but there is no 10% penalty for early withdrawal
  • It is possible to maintain both a 457 & 403b or a 457 & 401k and make maximum contributions to both
  • Can also have an IRA along with the 457
74
Q

Corporate-Sponsored Retirement Plans

A
  • ERISA is a federal legislation that regulates the establishment & management of corporate pension or retirement plans, also known as PRIVATE-SECTOR PLANS
  • All qualified corporate plans must be established under a trust agreement
  • A trustee is appointed for each plan & has a fiduciary responsibility for the plan & the beneficial owners (the plan holders)
75
Q

Defined Contribution Plans

A
  • Examples include money purchase pension plans as well as profit-sharing plans and 401k plans
  • Maximum employer contribution is significantly higher
  • Participants’ funds accumulate until a future event (retirement)
  • The ultimate account value depends on the total amount contributed along with the interest & capital gains from the plan investments
  • The plan participant assumes the investment risk
76
Q

Defined Benefit Plans

A
  • Designed to provide specific retirement benefits for participants, such as fixed monthly income
  • Regardless of investment performance, the promised benefit is paid under the contract terms
  • The plan sponsor assumed the investment risk
  • The benefit is usually determined by a formula that takes into account years of service & average salary for the last 5 years before retirement
  • Older, highly compensated employees are likely to have the largest annual contributions on their behalf
77
Q

Contributory vs Noncontributory Plans

A
  • Contributory plan both the employer & employee make contributions to the account
  • Noncontributory plan only the employer makes the contributions
  • Example of contributory is the 401k plan where the employee determines how much to contribute and the employer may match it up to a certain percentage
78
Q

Employer Deductions

A
  • Employer can usually deduct - subject to limits - contributions made to a qualified plan
  • Deduction limits depend on the kid of plan in place

Series 7 (4 decks)

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