fb-regbi-0005

status: publishedversion: v1corpus: 2026.9key: derivedseverity: high

Scenario (all facts stipulated)

{
  "customer": "Retail customer with a documented balanced-income profile.",
  "recommendation": "The associated person recommends an intermediate-term bond fund that matches the customer's profile.",
  "stipulated_facts": [
    "The firm performed full product diligence; the fund fits the customer's documented profile.",
    "No written disclosure of the scope and terms of the relationship, the firm's capacity, or the fees and costs was provided before or at the time of the recommendation; the firm planned to deliver it with the trade confirmation a week later.",
    "This is a single recommendation, not part of a series."
  ]
}

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-customer-specific — It violates the care obligation's customer-specific prong
violates-disclosure — It violates the disclosure obligation (written disclosure prior to or at the time of the recommendation)

Answer key

violates-disclosure

Derivation from the cited text

The disclosure obligation requires that the broker, prior to or at the time of the recommendation, provide the retail customer written full and fair disclosure of the required material facts. The stipulated facts state no such disclosure was provided before or at the time — a planned delivery a week later with the confirmation does not satisfy the quoted timing requirement. The product diligence and profile match rule out the care-obligation options.

Rubric

Selects violates-disclosure on the timing requirement in the quoted text.

Cited primary sources (quote-gated)

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-a (5/5 caught)adjudicated by: — (none required or pending)

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

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

The answer key correctly identifies that the failure to provide written disclosure prior to or at the time of the recommendation violates the disclosure obligation under sec-regbi (a)(2)(i).

deepseek-v4-proagrees the key is correctquote matched

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

The quoted provision requires written full and fair disclosure before or at the time of the recommendation. The stipulated facts state no such written disclosure of scope, terms, capacity, fees, or costs was provided before or at that time; a planned delivery a week later does not satisfy the timing requirement. The care obligation's customer-specific prong is not violated because the fund fits the customer's profile and full diligence was performed.

Version history & errata

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