fb-roll-0003

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

Scenario (all facts stipulated)

{
  "arrangement": "An investment adviser firm relying on PTE 2020-02 recommends a rollover and provides, before the transaction, a written description of its services and material Conflicts of Interest plus the written documentation of specific reasons for the rollover.",
  "stipulated_facts": [
    "No written acknowledgment that the Financial Institution and its Investment Professionals are fiduciaries was ever provided; the adviser mentioned fiduciary status orally in a phone call.",
    "All other quoted conditions are stipulated satisfied."
  ]
}

Question posed to the model under test

Judged only against the PTE 2020-02 conditions quoted in this item's sources, which conclusion follows about this arrangement? Answer with exactly one option id.

Answer options

satisfies-conditions — The stipulated facts satisfy the quoted conditions
fails-fiduciary-acknowledgment — It fails the written fiduciary-acknowledgment condition (Section II(b)(1))
fails-pre-rollover-disclosure — It fails the pre-rollover disclosure of documented reasons (Section II(b)(3))

Answer key

fails-fiduciary-acknowledgment

Derivation from the cited text

Section II(b)(1) requires a written acknowledgment of fiduciary status. The stipulated facts state fiduciary status was mentioned only orally; an oral statement does not satisfy a condition the quoted text defines as a written acknowledgment. The documented reasons were provided before the rollover, so II(b)(3) is satisfied.

Rubric

Selects fails-fiduciary-acknowledgment; oral disclosure does not meet a written-acknowledgment condition.

Cited primary sources (quote-gated)

PTE 2020-02, 85 FR 82798 · Section II(b)(1)

“A written acknowledgment that the Financial Institution and its Investment Professionals are fiduciaries under Title I and the Code”

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

“(1) A written acknowledgment that the Financial Institution and its Investment Professionals are fiduciaries under Title I and the Code” — dol-pte-2020-02

The answer key correctly identifies that Section II(b)(1) of PTE 2020-02 requires a 'written acknowledgment' of fiduciary status. Since the stipulated facts state that this acknowledgment was only provided orally, the arrangement fails this specific condition. The key also correctly notes that the pre-rollover disclosure of documented reasons was satisfied.

deepseek-v4-proagrees the key is correctquote matched

“A written acknowledgment that the Financial Institution and its Investment Professionals are fiduciaries under Title I and the Code” — dol-pte-2020-02

Section II(b)(1) expressly requires a written acknowledgment of fiduciary status. The stipulated facts state no written acknowledgment was ever provided; fiduciary status was mentioned only orally. An oral statement does not satisfy a written acknowledgment condition. The other rollover disclosure condition II(b)(3) is stipulated satisfied, so the only failure is the fiduciary acknowledgment.

Version history & errata

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