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Run: Regulation Best Interest (Reg BI) Disclosure Documentation Checklist

Use this Regulation Best Interest (Reg BI) Disclosure Documentation Checklist to verify that each retail customer recommendation file includes the required d...

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Inspection Setup and Recommendation Scope

Record the retail customer name or account identifier and the specific recommendation reviewed.
Confirm the date and time the recommendation was made or documented.
Identify the security, account type, or investment strategy covered by the recommendation.
Mark all supporting records present in the file, such as disclosures, notes, emails, suitability analysis, and approvals.

Disclosure Delivery and Timing

Confirm the customer was informed of the capacity in which the firm and representative were acting before or at the time of the recommendation.
Confirm the file shows disclosure of material fees, costs, and compensation associated with the recommendation.
Confirm any material limitations, product constraints, or platform restrictions were disclosed to the retail customer.
Record how the disclosure was delivered to the customer.
Rate whether the timing of disclosures was sufficient for the customer to consider the information before the recommendation was acted upon.

Conflict of Interest Identification and Mitigation

Confirm the file identifies any material conflict of interest relevant to the recommendation.
Confirm the file documents how the conflict was mitigated or eliminated, as applicable.
Confirm the file addresses compensation, sales contest, quota, or other incentive-related conflicts.
Confirm any required conflict disclosure was reviewed or approved by the appropriate supervisory or compliance function.
Rate whether the conflict documentation is specific, complete, and traceable to the recommendation file.

Care Obligation and Recommendation Basis

Confirm the file contains relevant customer profile information used in the recommendation, such as age, investment objectives, risk tolerance, financial situation, and time horizon.
Confirm the file explains why the recommendation was believed to be in the retail customer’s best interest.
Confirm the file includes reasonable alternatives considered and why the selected recommendation was preferred.
Rate whether the rationale is specific, supportable, and tied to the customer profile and product characteristics.

Supervision, Recordkeeping, and Closeout

Confirm the recommendation file was reviewed by the required supervisory or compliance reviewer.
Confirm any exceptions, deficiencies, or non-conformances were documented in the file.
Confirm corrective action was assigned when deficiencies were identified.
Inspector signature confirming the review is complete and accurate.

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