Description

A focused course, tailored for you

The Retail Brokerage Compliance Officer's Reg BI Evidence Playbook

Turn Reg BI, Form CRS, and FINRA 3110 expectations into a defensible evidence trail your examiners accept on the first pass.

The next FINRA or SEC exam will ask for the rollover file, the Form CRS delivery proof, and the supervisory review evidence. You know which three artefacts they will open first. The question is whether your compliance team can produce them, dated, signed off, and tied to the recommendation event, without a two-week scramble.

$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

Retail brokerage compliance officers sit between a rule set that has matured (Reg BI, Form CRS, FINRA Rule 3110, Rule 2111, Rule 4512, the Marketing Rule for any wrap or advisory adjacency) and a supervisory infrastructure that was built for a pre-Reg BI world. The supervisory questionnaires reference suitability language. The exception reports flag dollar thresholds, not best-interest factors. Form CRS delivery is logged in one system, the recommendation is logged in another, and the rollover analysis lives in a registered representative's notes. When the exam request letter arrives asking for the recommendation evidence on a specific account on a specific date, the compliance officer has to manually reconcile three or four systems to assemble the file. This course replaces that scramble with a documented evidence model: which artefact, in which system, owned by which supervisor, refreshed on which cadence, surfaced on which exception report, and tied to which Reg BI prong.

What you walk away with

A documented Reg BI evidence model that ties each prong (Care, Disclosure, Conflict, Compliance) to specific artefacts, owners, and refresh cadences.
A rebuilt supervisory questionnaire and rollover comparison worksheet that produce defensible records on every recommendation.
An exam-ready file structure that lets you respond to a regulator request in days, not weeks.
A conflict disclosure register reconciled against your firm's actual conflicts inventory and tied to Form CRS delivery events.
A Rule 3110 supervisory exception model that surfaces best-interest red flags, not just dollar thresholds.

The 12 modules

Module 1. Mapping the Reg BI evidence universe

Reg BI is four obligations. Each obligation has a defensible artefact set. This module catalogues every artefact the SEC and FINRA have asked for in the past two examination cycles, mapped to Care, Disclosure, Conflict, and Compliance. You leave with a single-page artefact-to-prong matrix tuned to your business mix, plus the evidence gaps your current supervisory program does not yet produce.

Module 2. Rebuilding the rollover recommendation file

Rollover recommendations sit at the top of every recent enforcement matter. This module walks through a defensible rollover comparison worksheet: plan fees vs IRA fees, services in vs services out, investment options, fiduciary status, the specific reasons this account holder is better off. You leave with a worksheet template and a supervisory review path that survives a 211 referral and a state regulator joint exam.

Module 3. Form CRS delivery and the recommendation event

Form CRS has to be delivered at the right moment to the right person and the delivery has to be provable. This module ties the Form CRS delivery log to the account opening event, the new recommendation event, and the material change event. You build a delivery reconciliation report that shows zero gaps when the examiner asks for the proof on a specific account on a specific date.

Module 4. FINRA Rule 3110 supervisory framework refresh

Most supervisory written procedures still read like suitability documents. This module rewrites the WSPs around Reg BI logic: best-interest reviews on every recommendation, heightened reviews on complex or high-cost products, documented exception escalation, periodic principal review with documented evidence. You leave with a WSP refresh checklist and a redlined section structure ready for your General Counsel.

Module 5. Conflict identification and the disclosure register

Reg BI's Conflict Obligation requires you to identify, disclose, and where appropriate mitigate or eliminate conflicts. This module builds a conflict register that reconciles against the firm's revenue lines, compensation grids, and product preferences. The register ties to Form CRS, to the firm brochure where applicable, and to the supervisory review of any recommendation touching a conflicted product.

Module 6. Cash sweep, money market, and uninvested cash

Uninvested cash is one of the most active regulatory topics for retail brokerage. This module addresses cash sweep program selection, disclosure of yield differentials, supervisory review of the sweep recommendation, and the documentation file required to defend the sweep choice as a best-interest decision. You build a sweep program review template and a quarterly attestation pack.

Module 7. Variable annuity, fixed indexed annuity, and complex product supervision

Annuity recommendations carry heightened supervisory expectations under both Reg BI and Rule 2330. This module walks through the suitability and best-interest documentation file, the principal review path, the exception triggers, and the conflicts disclosure required when the firm receives differential compensation. Templates included for the recommendation worksheet and the principal sign-off.

Module 8. Marketing Rule adjacency for dually registered firms

If your firm is dually registered or has an advisory affiliate, the Marketing Rule sits next to Reg BI in every exam. This module addresses the touchpoints: testimonials, endorsements, performance presentations, hypothetical illustrations, and the supervisory review of marketing content. You leave with a marketing review log structure that ties to Form CRS and to the conflict disclosure register.

Module 9. Exception report design for best-interest supervision

Most exception reports still flag dollar thresholds. Best-interest supervision requires exception logic on recommendation patterns, product mix, cost differentials, and supervisor-to-representative ratios. This module designs an exception report set that surfaces what Reg BI actually cares about. You leave with the exception logic specifications and the supervisory disposition documentation model.

Module 10. Exam readiness file structure and response cadence

When the exam request letter arrives, the clock starts. This module designs an exam response file structure that lets you assemble account-level evidence in days. The structure ties recommendation events to supervisory reviews, to disclosures delivered, to the conflicts register entry, and to the WSP section authorising the activity. Templates for the response cover memo, the artefact index, and the supervisor attestation.

Module 11. Branch and OSJ supervision under Reg BI

Branch office and OSJ supervisors carry first-line Reg BI responsibility. This module addresses the supervisory questionnaire refresh, the branch inspection program adjustments, the heightened supervision regime for repeat-issue representatives, and the documentation chain from registered representative recommendation through OSJ principal review through home office surveillance. Branch-ready templates included.

Module 12. Annual Reg BI compliance program review

Rule 17a-5 and Rule 3120 expect documented annual reviews. This module walks through the annual review structure: testing methodology, sampling logic, findings documentation, remediation tracking, and the certification that the program is reasonably designed to achieve compliance. You leave with the annual review template, the sampling plan, and the report-out memo structure for the CCO.

How this addresses your situation

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

The exam request letter asks for the rollover recommendation file on a specific account.

The home office wants to know whether the cash sweep change was reviewed as a best-interest decision.

Internal audit wants evidence that Form CRS was delivered at the right moment on the right account.

A registered representative escalates a complex product recommendation and the WSPs do not give a clean review path.

What you get with this course

Twelve written modules in the Art of Service learning environment.
Downloadable templates: Reg BI artefact matrix, rollover comparison worksheet, Form CRS delivery reconciliation, WSP refresh checklist, conflict register, cash sweep review template, exception report specifications, exam response file structure, branch supervisory questionnaire, annual review pack.
Worked examples drawn from publicly available enforcement actions and exam priority letters.
Hand-built implementation playbook tuned to your supervisory structure and product mix, delivered alongside course access.
30-day money-back guarantee.

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

Within 24 hours: account provisioned, course access granted, hand-built implementation playbook delivered.

Week one: complete modules 1 to 4 and run the Reg BI artefact matrix exercise against your current evidence set.

Weeks two and three: complete modules 5 to 9, rewrite the WSP section structure, redesign the exception report logic.

Week four: complete modules 10 to 12, assemble an exam-readiness file dry run, schedule the annual review pack walkthrough.

Before and after

Before

Exam request letters trigger a two-week reconciliation across three or four systems. WSPs read like suitability documents. Exception reports flag dollar thresholds, not best-interest logic. Form CRS delivery proof requires manual reconciliation. Rollover files vary by representative. The annual review is assembled at the end rather than evidenced through the year.

After

Exam request letters trigger a structured response in days. WSPs map cleanly to Reg BI obligations. Exception reports surface best-interest red flags. Form CRS delivery reconciles to recommendation events automatically. Rollover files follow a single defensible worksheet. The annual review pack assembles itself from evidence captured continuously.

What happens if you do not address this

The next FINRA exam cycle is already running heightened Reg BI testing, with rollover, cash sweep, and complex product recommendations leading the priority list. Firms whose evidence model still resembles pre-Reg BI suitability documentation are running on borrowed time. The cost of a deficiency letter is months of remediation, a public Wells notice in the worst case, and reputational damage that flows directly to the CCO and the supervisory chain.

Who it is for

Compliance officer, compliance manager, or supervisory principal at a US retail brokerage, wealth management, or dually registered firm. Responsible for Reg BI, Form CRS, Rule 3110 supervision, rollover and cash sweep recommendations, exception report review, and exam readiness. Sits between the business, the field supervisors, internal audit, and the regulators. Holds Series 7, 24, and often 65 or 66. Reports to a CCO or Director of Supervision.

Who this is NOT for. Not for institutional compliance, swap dealer compliance, or pure investment adviser CCOs whose business does not touch Reg BI. Not for sell-side equity research compliance. Not for AML-only roles where Reg BI sits with a different team. The course assumes the reader supervises or audits registered representatives making recommendations to retail customers.

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. Twenty to thirty hours of focused work spread over four weeks. Each module is designed to be completed in a single sitting of ninety minutes to two hours, with template work running in parallel.

Why $199 is the right number

Compliance consultancies will deliver a similar evidence model for tens of thousands of dollars and a six-month engagement. National training providers offer Reg BI overview courses that stop at rule familiarisation. This course assumes you already know the rule and works at the level of the actual artefacts your examiner will open, with a per-buyer implementation playbook tuned to your firm's supervisory structure.

FAQ

Is this aimed at the CCO or the line supervisor?

Both. The CCO uses the artefact matrix, conflict register, and annual review pack. Branch and OSJ supervisors use the questionnaire refresh, exception logic, and rollover worksheet. The implementation playbook splits the work by role.

Does the course cover advisory side Form ADV obligations?

It covers the adjacencies that touch Reg BI and Form CRS for dually registered firms. Pure Form ADV Part 2A drafting is out of scope and better handled by a dedicated investment adviser compliance course.

Will the templates plug into our existing GRC or compliance tooling?

Yes. Templates are provided in editable formats and as structured field lists that map cleanly to common GRC platforms used in retail brokerage compliance.

What does the implementation playbook include?

A document tuned to your supervisory structure, product mix, and channel model. It sequences the twelve modules in the order that matters most given your current evidence gaps and names the artefacts to produce in week one.

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.