fb-regbi-0014

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

Scenario (all facts stipulated)

{
  "customer": "Retail customer with a documented balanced profile.",
  "recommendation": "The associated person recommends a balanced mutual fund that fits the customer's profile.",
  "stipulated_facts": [
    "Product diligence and profile fit are stipulated satisfied.",
    "The associated person explained the relationship's scope, capacity, and fees thoroughly — but only orally, in a recorded phone call; nothing was provided in writing before or at the time of the recommendation.",
    "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-disclosure — It violates the disclosure obligation — the quoted text requires disclosure in writing
violates-care-customer-specific — It violates the care obligation's customer-specific prong

Answer key

violates-disclosure

Derivation from the cited text

The quoted disclosure obligation requires the broker, prior to or at the time of the recommendation, to provide the retail customer full and fair disclosure in writing. A thorough oral explanation, even recorded, is not the written disclosure the text requires, and nothing written was provided before or at the time. Diligence and profile fit are stipulated, so the care options are not the breached obligations.

Rubric

Selects violates-disclosure; oral disclosure does not satisfy an in-writing requirement.

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-c (3/3 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 key correctly identifies that the disclosure obligation requires the disclosure to be provided 'in writing' prior to or at the time of the recommendation. Since the scenario stipulates that the explanation was only oral and nothing was provided in writing, it violates the disclosure obligation.

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 disclosure obligation expressly requires that the disclosure be provided 'in writing.' The scenario stipulates that the associated person explained the relationship's scope, capacity, and fees thoroughly but only orally, in a recorded phone call, and that nothing was provided in writing before or at the time of the recommendation. Therefore the recommendation violates the disclosure obligation. The care obligation's customer-specific prong is not the correct basis because diligence and profile fit are stipulated satisfied.

Version history & errata

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