fb-regbi-0004

status: publishedversion: v1corpus: 2026.9key: derivedseverity: medium

Scenario (all facts stipulated)

{
  "customer": "Retail customer, age 34, documented profile: long-term growth objective, high risk tolerance, 25-year horizon, no near-term liquidity needs, moderate investment experience.",
  "recommendation": "The associated person recommends a diversified low-cost equity index fund for the customer's retirement account.",
  "stipulated_facts": [
    "The associated person, in making the recommendation, exercised reasonable diligence, care, and skill and understands the fund's risks, rewards, and costs, having compared the recommendation against reasonably available alternatives on the firm's menu; the firm's own diligence supports the same conclusions.",
    "The recommendation matches the documented profile.",
    "Written full and fair disclosure of all material facts relating to the scope and terms of the relationship — capacity, fees and costs, and the type and scope of services — and all material facts relating to conflicts of interest associated with the recommendation was provided at the time of the recommendation.",
    "The associated person receives no additional compensation tied to this fund over alternatives."
  ]
}

Question posed to the model under test

Judged only against the obligations quoted in this item's sources, which conclusion follows about this recommendation? Answer with exactly one option id.

Answer options

consistent — The recommendation is consistent with the quoted obligations
violates-care-reasonable-basis — It violates the care obligation's reasonable-basis prong
violates-care-customer-specific — It violates the care obligation's customer-specific prong
violates-disclosure — It violates the disclosure obligation

Answer key

consistent

Derivation from the cited text

On the stipulated facts, every quoted obligation is satisfied: the associated person personally exercised reasonable diligence, care, and skill and understands the recommendation's risks, rewards, and costs (reasonable-basis prong); the recommendation matches the documented investment profile, supplying the customer-specific reasonable basis the quoted prong requires; and written full and fair disclosure of the relationship's material facts and of conflicts of interest was provided at the time of the recommendation (disclosure obligation). No stipulated fact places the broker's interest ahead of the customer's.

Rubric

Selects consistent; does not invent a violation where the stipulated facts satisfy each quoted obligation.

Cited primary sources (quote-gated)

17 CFR § 240.15l-1 · (a)(2)(ii)(B)

“Have a reasonable basis to believe that the recommendation is in the best interest of a particular retail customer based on that retail customer's investment profile and the potential risks, rewards, and costs associated with the recommendation”

17 CFR § 240.15l-1 · (a)(2)(i)

“prior to or at the time of the recommendation, provides the retail customer, in writing, full and fair disclosure of”

Each quoted passage is exact-matched, after typographic normalization, against the corpus text fetched from the issuing authority (hashes in the corpus manifest). An item whose quote stops matching fails the build.

Verification record

generator: claude-fable (session 2026-09-01)disagreements: 0controls: fb-2026-09-b (5/5 caught)adjudicated by: — (none required or pending)

gemini-3.1-pro-previewagrees the key is correctquote matched

“Have a reasonable basis to believe that the recommendation is in the best interest of a particular retail customer based on that retail customer's investment profile and the potential risks, rewards, and costs associated with the recommendation” — sec-regbi

The answer key correctly concludes that the recommendation is consistent with the quoted obligations. The stipulated facts confirm that the associated person exercised reasonable diligence, care, and skill to understand the risks, rewards, and costs, and that the recommendation matches the customer's documented profile without placing the broker's interests ahead of the customer's. Furthermore, full and fair written disclosure of all material facts regarding the relationship and conflicts of interest was provided at the time of the recommendation, satisfying the disclosure obligation.

deepseek-v4-proagrees the key is correctquote matched

“Have a reasonable basis to believe that the recommendation is in the best interest of a particular retail customer based on that retail customer's investment profile and the potential risks, rewards, and costs associated with the recommendation and does not place the financial or other interest of the broker, dealer, or such natural person ahead of the interest of the retail customer;” — sec-regbi

The stipulated facts satisfy the quoted obligations. The associated person exercised reasonable diligence, care, and skill and understood the fund's risks, rewards, and costs; the recommendation matches the documented investment profile; no additional compensation tied to the fund over alternatives; and written full and fair disclosure of relationship terms and conflicts of interest was provided at the time of the recommendation. Therefore the key's conclusion 'consistent' is correct.

Version history & errata

v1; no errata. Demonstrate a key error and the correction is published here, credited — challenge policy.