Description

A focused course, tailored for you

The Retail Brokerage Bank Reg BI and Reg W Evidence Playbook

A working file of Reg BI Care Obligation, Reg W affiliate exposure caps, and the Issue Log entries that survive the FINRA exam interview.

You sit between a national bank charter and an affiliated broker-dealer. The Issue Log entries you write are read by OCC examiners, FINRA examiners, internal audit, and the second-line testing team, and each one wants different wording on the same underlying finding.

$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

Senior Compliance Managers at retail brokerage banks own the intersection where bank regulation and broker-dealer regulation collide, and the highest-friction artefact in that intersection is the Issue Log entry. The same finding has to read as a Reg BI Care Obligation gap to FINRA, a Reg W 23A affiliate exposure question to the OCC, a UDAAP disclosure issue to the CFPB if the sweep is consumer-facing, and an operational risk event to the second-line testing team. The wording the retail platform PM uses in the remediation plan determines whether the exam team closes the finding in one cycle or opens a matter requiring attention. The second-line reviewer rewords the entry, the retail platform PM pushes back, the legal team asks for a third version, and the underlying remediation slips a quarter. The working file that holds up across all four readers is what a Senior Compliance Manager actually needs.

What you walk away with

Issue Log entries that read cleanly to OCC, FINRA, CFPB, and internal audit on the first version.
A Reg W 23A affiliate exposure memo that names the cap calculation, the covered transaction list, and the carve-outs in language the OCC team will sign off on.
A Reg BI Care Obligation evidence package for cash-sweep disclosures that holds up in a FINRA cycle exam interview.
An eight-question script that hands a remediation plan to the retail platform PM with the correct owner, scope, and target date the first time.
A working file structure that the second-line testing team, the legal team, and the retail platform PM all draw from without rewording.

The 12 modules

Module 1. The dual-regulator Issue Log entry that survives the joint exam

The wording that reads as a Reg BI Care Obligation gap to FINRA and a Reg W affiliate exposure question to the OCC simultaneously. Covers the seven-line entry template, the remediation owner field, the regulatory citation block, and the target date convention that the second-line testing team will accept without rewording. Includes the three Issue Log entries that the FINRA team will read first in any retail brokerage bank exam, and how to phrase them so the examiner moves past in under five minutes.

Module 2. Reg W 23A affiliate exposure caps for the sweep program

The covered transaction definition, the ten percent capital cap and twenty percent aggregate cap, the carve-outs for fully secured transactions, and the collateral haircut schedule. Worked example calculation for a cash-sweep program that runs from the broker-dealer customer accounts into the affiliated bank money market deposit account. Includes the quarterly attestation template the OCC will request and the Reg W 23A memo language that holds up under exam.

Module 3. Reg BI Care Obligation evidence for cash-sweep disclosures

The four-prong Care Obligation test applied to a sweep program where the affiliated bank pays a lower rate than non-affiliated alternatives. The customer-specific cost-benefit documentation, the reasonable basis recommendation file, the disclosure timing evidence, and the conflict mitigation log. Covers the FINRA exam interview script for the Care Obligation, including the three questions the examiner always asks and the answers that close the finding in one cycle.

Module 4. The Reg BI Conflict of Interest Obligation in an affiliated structure

Identifying conflicts that arise from the broker-dealer recommending products of the affiliated bank, the affiliated trust company, and the affiliated advisor. The Conflict Disclosure document template, the mitigation log, and the elimination decision memo for conflicts that cannot be disclosed. Includes the Reg BI Conflict Obligation language for a retail brokerage that runs a proprietary mutual fund family and a separately managed account program.

Module 5. Form CRS for the dual-registrant household

Drafting Form CRS for a household that holds a brokerage account at the affiliated broker-dealer, an advisory account at the affiliated investment adviser, and a deposit account at the affiliated bank. The conversation starters that the FINRA team will probe in exam interviews, the relationship summary fee disclosure, and the standard of conduct language. Covers the Form CRS update triggers and the delivery evidence file.

Module 6. UDAAP exposure on cash-sweep program disclosures

The CFPB UDAAP framework applied to a retail brokerage bank cash-sweep program where customers reasonably expect the highest available yield. The unfair, deceptive, and abusive prongs worked through with the specific disclosure language that triggers each. Includes the customer complaint log review template, the disclosure timing evidence, and the CFPB exam interview script for UDAAP.

Module 7. The retail platform PM remediation handoff script

The eight-question script that hands a remediation plan to the retail platform product manager with the correct owner, scope, and target date the first time. Covers the Issue Log entry the PM reads, the scope-of-change memo, the affected customer population calculation, the regulatory citation block, and the target date convention. Includes the three escalation paths when the PM pushes back on the scope or the date.

Module 8. Joint OCC and FINRA exam prep working file

The single working file the bank compliance team and the broker-dealer compliance team draw from in the weeks before a joint exam cycle. The Issue Log entries that are closed, the open remediation items with target dates, the policy refresh log, the training completion roster, and the prior-cycle exam findings with current status. Covers the live exam interview prep including the questions both exam teams will ask in the first hour.

Module 9. Reg BI Care Obligation for rollovers from the affiliated bank IRA

The four-prong Care Obligation test applied to rollovers from an affiliated bank traditional IRA into a brokerage account at the affiliated broker-dealer. The customer-specific cost-benefit documentation that compares the bank IRA fee schedule to the brokerage account fee schedule, the reasonable basis recommendation file, and the rollover disclosure timing evidence. Includes the FINRA exam interview script for IRA rollover Care Obligation.

Module 10. Reg W 23B market terms for affiliate transactions

The market terms requirement applied to transactions between the broker-dealer and the affiliated bank, including services agreements, technology platform sharing, customer referral fees, and shared facilities. The benchmark documentation template, the third-party comparable evidence file, and the quarterly attestation. Covers the Reg W 23B exam questions the OCC team will ask and the market terms memo language that holds up under exam.

Module 11. Second-line testing program for the joint Issue Log

The testing methodology the second-line team uses to validate Issue Log entries written by the first-line compliance team. The sampling approach, the testing script for Reg BI, Reg W, and UDAAP entries, the testing workpaper template, and the disposition memo. Includes the three findings the second-line team most often raises on first-line Issue Log entries and the wording adjustments that close those findings without a rewrite cycle.

Module 12. The Compliance Manager's quarterly artefact pack for the CCO and GC

The quarterly report the Senior Compliance Manager hands up to the Chief Compliance Officer and the General Counsel. The Issue Log status summary, the open remediation items, the exam readiness rating, the policy refresh log, the training completion roster, the regulatory horizon scan, and the resource ask. Covers the GC's three standard questions and the answers that close the meeting in twenty minutes.

How this addresses your situation

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

Module 1 wording is what you use the next time the second-line reviewer flags an Issue Log entry as the wrong regulation.

Module 3 evidence package is what closes the Reg BI Care Obligation finding the FINRA team will open on the cash-sweep program.

Module 7 script is what you use the next time the retail platform PM pushes back on a remediation scope.

Module 8 working file is what the bank and broker-dealer second-line teams draw from in the weeks before the next joint exam.

What you get with this course

Written course in the Art of Service learning environment, 12 modules, self-paced.
Downloadable Issue Log entry template tuned for dual-regulator readers.
Reg W 23A affiliate exposure cap calculation worksheet with worked sweep program example.
Reg BI Care Obligation evidence package template for cash-sweep disclosures.
Eight-question retail platform PM remediation handoff script.
Joint OCC and FINRA exam prep working file structure.
Hand-built implementation playbook delivered alongside course access, tuned to your specific affiliate structure.

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

Within 24 hours: account provisioned in the Art of Service learning environment, all 12 modules accessible, templates downloadable.

Within 24 hours: hand-built implementation playbook delivered alongside course access, tuned to your specific affiliate structure and the next exam cycle on your calendar.

Before and after

Before

You write an Issue Log entry, the second-line reviewer reframes it, the legal team asks for a third version, the retail platform PM pushes back on scope, and the remediation slips a quarter while the exam cycle approaches.

After

You write an Issue Log entry once, the second-line reviewer signs it off, the legal team accepts the wording, the retail platform PM takes the remediation with the correct scope and target date, and the exam team closes the finding in one cycle.

What happens if you do not address this

The next joint exam cycle opens a matter requiring attention on a finding that should have closed in one cycle, the remediation date slips two quarters, the CCO has to brief the GC and the bank board on a public regulatory action, and the resource ask for next year is denied because the prior cycle did not close cleanly.

Who it is for

A Senior Compliance Manager at a retail brokerage that runs inside or alongside a national bank charter. Owns Reg BI, Reg W 23A and 23B, the affiliate sweep program, the cash management disclosure stack, and the joint Issue Log that the bank and broker-dealer second-line teams share. Reports into a Chief Compliance Officer who reports into the General Counsel. Spends roughly forty percent of the week on Issue Log entries, twenty percent on remediation tracking, twenty percent on exam prep and live exam interviews, and the rest on policy refresh and training sign-off.

Who this is NOT for. Pure broker-dealer compliance managers who never touch the bank charter. Pure bank BSA officers who never touch the broker-dealer. Legal counsel who write policy but do not own the Issue Log. Anyone whose firm does not run an affiliated bank and broker-dealer under one corporate umbrella.

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 six to eight hours across the 12 modules. Modules 1, 3, 7, and 8 are the highest-leverage and can be worked through in two focused sittings before the next exam cycle.

Why $199 is the right number

FINRA Institute and SIFMA Compliance and Legal Society offer broker-dealer compliance training that does not address the dual-regulator Issue Log problem. ABA and RMA offer bank compliance training that does not address Reg BI or Form CRS. Big4 consulting on the affiliate structure runs into the high five figures and does not produce a Compliance Manager's working file. This is the only $199 working file tuned to the Senior Compliance Manager at a retail brokerage bank.

FAQ

Does this assume my firm runs the broker-dealer inside the bank holding company or as a separate affiliate?

The course covers both structures. The Reg W 23A cap calculation and the Reg BI Conflict Obligation work differently depending on the structure, and both versions are worked through.

Is the implementation playbook a generic document or actually tuned to my firm?

The playbook is hand-built after purchase against the specific affiliate structure, the cash-sweep program type, and the next exam cycle on your calendar. Delivered alongside course access.

What if my firm does not run a cash-sweep program?

The Reg BI Care Obligation framework in module 3 applies to any product recommendation where the affiliated bank or affiliated advisor pays a lower yield or higher fee than non-affiliated alternatives. The cash-sweep is the worked example. The framework generalises.

How does this differ from FINRA's own Reg BI training?

FINRA training covers the rule. This course covers the Issue Log entry, the Care Obligation evidence package, the second-line testing script, and the retail platform PM handoff. The artefacts a Senior Compliance Manager actually writes.

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.