Description

A focused course, tailored for you

The Reg BI Care Obligation Testing Playbook for Broker-Dealer Compliance

A repeatable testing program for Reg BI care, conflicts, and disclosure that holds up under a FINRA cycle exam.

Your Reg BI testing matrix is solid on disclosure and conflicts. Care obligation is still mostly reviewer prose. That is the row a cycle exam request list will hit hardest.

$199 one-time

Tailored to your situation. Access within 24 hours. 30-day money-back.

Includes a hand-built implementation playbook delivered alongside course access, generated for your specific situation.

Why this course

Compliance officers running a Reg BI testing program at a US broker-dealer or dual registrant know the shape of the artefacts an examiner expects: a documented methodology, a defensible sample, structured reviewer evidence, a disposition log, and a remediation track. Disclosure and compliance obligations have settled into a steady rhythm. The care obligation row is the one that stays uneven. Reasonably available alternatives evidence is inconsistent across rollover recommendations, share class changes, mutual fund to advisory account moves, and complex product approvals. Reviewer notes are thoughtful but unstructured, which means a FINRA exam letter asking for the population, the sample, the disposition, and the evidence forces a scramble. Branch supervision evidence is collected separately, then stitched together at exam time. This is the playbook that ties the care obligation testing program into a single auditable spine: methodology, population, sample, reviewer guide, evidence templates, exception taxonomy, and a remediation log a regional compliance reviewer and a FINRA exam team both read the same way.

What you walk away with

A Reg BI care obligation testing methodology document examiners read as a controls artefact, not a memo.
Reasonably available alternatives evidence templates for rollover, share class, account type, and complex product recommendations.
A sample design that ties population, sampling logic, reviewer guide, and exception taxonomy into one auditable chain.
A conflicts inventory cross-linked to the Form CRS disclosure log and the testing matrix.
A remediation log that closes the loop from exception to retraining to retest, with timestamps a cycle exam team can verify.

The 12 modules

Module 1. The cycle exam request list as the testing program brief

Start from the artefacts a FINRA exam letter will ask for, then work backwards into the testing program. The module walks through a representative request list (methodology, population, sample, reviewer notes, exceptions, remediation, supervision evidence), shows where the care obligation row typically grades weakest, and produces a one-page testing-program scorecard the Chief Compliance Officer reads before the next exam window opens.

Module 2. Care obligation testing methodology document

The methodology is the artefact examiners read first. The module produces a methodology document covering population definition, sampling logic, reviewer qualifications, reviewer guide, evidence requirements, exception taxonomy, escalation thresholds, retest cadence, and management reporting. Includes a redline template for the version history examiners expect, plus a sign-off block tied to the legal and supervision functions.

Module 3. Population and sampling for rollover recommendations

Rollover recommendations are the highest-scrutiny care obligation population. The module defines the population (rollovers solicited by associated persons, by branch, by quarter), the sampling logic (risk-weighted by account size, age, and product type), and the reviewer guide that decomposes a rollover recommendation into the cost comparison, the alternatives considered, the rationale, and the client-specific factors that justified the recommendation.

Module 4. Reasonably available alternatives evidence template

Reviewer prose is the weakest link in care obligation evidence. The module replaces prose with a structured template covering the alternatives considered, the cost basis used, the product features compared, the client-specific factors weighted, and the source citation for the cost data. The template renders the same way for a rollover, a share class change, a mutual fund to advisory account move, and a complex product recommendation, so the exam team reads a single shape across populations.

Module 5. Share class and account type testing

Share class testing has been a long-running FINRA priority. The module covers the share class population definition, the breakpoint and waiver analysis, the eligible-class evidence requirements, the account type considerations (brokerage versus advisory), and the disposition logic for exceptions. Includes a worked example for a share class exception flagged in testing, escalated, remediated, retested, and closed in the remediation log.

Module 6. Complex product approvals and post-sale testing

Complex products (structured notes, non-traded REITs, alternatives, leveraged and inverse ETFs) attract higher care obligation scrutiny. The module covers the product approval evidence the testing program inherits from the new product committee, the additional reviewer guide for post-sale care testing, the client suitability and concentration triggers, and the linkage to the firm's product withdrawal and reapproval cycle.

Module 7. Conflicts inventory cross-linked to disclosure

The conflicts obligation is the testing row that touches every other obligation. The module produces a conflicts inventory tied to the Form CRS disclosure log, the Reg BI relationship summary, the firm's compensation grids, the third-party payment arrangements, and the proprietary product slate. Includes a mapping that shows for each tested recommendation which conflicts were identified, disclosed, and where they were disclosed.

Module 8. Branch supervision evidence linked to the testing matrix

Branch supervision and home-office testing are usually run as separate evidence streams. The module ties them into a single chain so the regional reviewer's notes on a care obligation recommendation flow into the testing matrix without duplicate review. Covers the branch reviewer guide, the home-office reviewer guide, the escalation path between them, and the supervision evidence template the cycle exam team reads as a single artefact.

Module 9. Exception taxonomy and disposition log

An exception taxonomy that separates documentation gaps, methodology gaps, and recommendation-quality concerns is how a testing program shows examiners it is operating at the right level. The module builds the taxonomy, the disposition codes, the reviewer-to-supervisor escalation rules, and the management reporting that summarises exceptions by branch, by product, and by associated person, with trend indicators the Chief Compliance Officer reads quarterly.

Module 10. Remediation track from exception to retest

Examiners read the remediation log as proof the program closes the loop. The module covers remediation owner assignment, retraining evidence, policy and procedure updates, supervisory follow-up, retest sampling logic, and closure criteria. Includes the timestamp chain examiners verify against the original exception and the closure entry, plus the management reporting that aggregates open and closed remediation items.

Module 11. Annual program assessment and committee reporting

The annual program assessment is the artefact that ties a year of testing into a single narrative for the audit committee, the legal function, and the executive principal. The module produces the assessment template covering coverage, exceptions by population, remediation closure rates, training adjustments, methodology changes, and forward-look priorities, plus the committee reporting package the Chief Compliance Officer presents.

Module 12. Cycle exam readiness binder

The cycle exam binder is the readiness artefact pulled together when the exam letter arrives. The module produces the binder structure (methodology, population, sample, reviewer guides, evidence templates, exceptions, remediation, supervision linkage, conflicts, annual assessment) and the mapping that ties each binder section to a likely request list item. Includes the cover memo template the Chief Compliance Officer signs and the version-control register the exam team accepts as the canonical record.

How this addresses your situation

Specific modules that map to what you said you are dealing with.

The cycle exam request list lands and the testing program has to be read as one chain, not eight binders. Modules 1, 2, 12.

The care obligation row is the weakest evidence shape in the testing matrix. Modules 3, 4, 5, 6.

Conflicts and supervision evidence sit in different systems and stitch together at exam time. Modules 7, 8.

The exception-to-remediation chain is how the program shows examiners it operates, not just tests. Modules 9, 10, 11.

What you get with this course

12 written modules in the Art of Service learning environment.
Downloadable templates: testing methodology, sampling design, reviewer guide, reasonably available alternatives evidence, exception taxonomy, remediation log, cycle exam readiness binder.
Worked examples for rollover, share class, complex product, and account type testing populations.
A hand-built implementation playbook delivered alongside course access, tuned to the firm's product slate and supervision structure.
30-day money-back guarantee.

What you will have in hand by Day 1, Week 1, Month 1

Within 24 hours: account in the Art of Service learning environment is provisioned and the hand-built implementation playbook is delivered alongside it.

Week 1: modules 1 to 3 (testing program scorecard, methodology document, rollover population and sampling).

Week 2: modules 4 to 6 (alternatives evidence template, share class testing, complex product testing).

Week 3: modules 7 to 9 (conflicts inventory, branch supervision linkage, exception taxonomy).

Week 4: modules 10 to 12 (remediation track, annual program assessment, cycle exam readiness binder).

Before and after

Before

Reg BI testing is a binder of reviewer notes that grades fine internally but slows down when a cycle exam request list arrives. Care obligation evidence is uneven across rollover, share class, and complex product populations. Branch supervision and home-office testing are stitched together at exam time.

After

The testing program reads as a single chain: methodology, population, sample, reviewer guide, structured evidence, exception taxonomy, remediation log, supervision linkage, annual assessment, exam binder. The care obligation row is the shape examiners expect, not reviewer prose. The exam team reads the binder once and the request list shrinks.

What happens if you do not address this

FINRA cycle exam findings on Reg BI care obligation testing methodology produce supervisory letters, enforcement referrals on repeat issues, and, at large broker-dealers, board-level reporting obligations. A testing program graded as a controls weakness becomes a multi-year remediation under examiner supervision.

Who it is for

Compliance Officer at a US broker-dealer or dual registrant who owns the Reg BI testing program, coordinates with branch supervision, sits across from the FINRA exam team during the cycle exam, and is responsible for the testing methodology, sample design, evidence templates, exception taxonomy, and remediation log that hold up under a request list.

Who this is NOT for. Not for retail registered representatives writing their own care obligation rationales, not for AML or trade surveillance specialists whose testing program follows a different rulebook, and not for compliance leaders at firms that have outsourced Reg BI testing to a consultancy and are not rebuilding the program in-house.

How it arrives

Text-based course in the Art of Service learning environment, plus downloadable templates and worked examples for every module, plus the hand-built implementation playbook delivered alongside course access.

Time investment. Roughly 8 to 12 hours across four weeks if worked in sequence. The templates are usable from week one; the binder structure pays back the first time a cycle exam letter arrives.

Why $199 is the right number

A consultancy engagement to rebuild the Reg BI testing program typically runs into six figures and lands as a methodology deck and a sample of templates. Internal rebuilds pull a senior compliance officer off the desk for a quarter. This course delivers the artefacts directly, tuned to the firm's product slate, at a price point that does not require a procurement cycle.

FAQ

Is this aligned to the SEC Reg BI release and FINRA's published exam priorities?

Yes. The methodology references the four obligations as defined in the SEC release and tracks the testing themes FINRA has highlighted in recent exam priorities and report letters.

Does it cover dual registrant considerations?

Yes. The conflicts inventory and the alternatives evidence template are built to accommodate the brokerage and advisory account comparison that dual registrants face on rollover and account type recommendations.

Who hand-builds the implementation playbook?

Gerard Blokdyk hand-builds it after purchase, tuned to your firm's product slate, branch structure, and current testing matrix. Delivered alongside course access.

What if the program needs adjustments after exam findings?

The exception taxonomy and remediation track module is designed to integrate findings into the program without restarting the methodology. The annual program assessment module captures methodology changes formally.

30-day money-back guarantee. If after a week of working through the materials this is not what you needed, reply to the receipt email and a full refund is processed. No questions, no forms.

Within 24 hours your account in the learning environment is provisioned and the tailored implementation playbook is delivered alongside it.