fb-roll-0005
{
"arrangement": "A fintech platform generates rollover recommendations solely through an interactive website: software models produce the advice from information each investor supplies online.",
"stipulated_facts": [
"No Investment Professional ever interacts with the investor or reviews the individual recommendation — the advice is generated entirely by the software (robo-advice).",
"The platform provides written fiduciary acknowledgments, conflict disclosures, and rollover-reason documentation, and observes the Impartial Conduct Standards.",
"The platform wishes to rely on PTE 2020-02 for the variable compensation it receives on these rollovers."
]
}May this platform rely on PTE 2020-02 for these transactions? Answer with exactly one option id.
yes-conditions-met— Yes — the Section II conditions are all satisfiedexcluded-robo-advice— No — Section I(c)(2) excludes advice generated solely by an interactive website without personal interaction with an Investment Professionalfails-rollover-documentation— No — the rollover-documentation condition is unmet
excluded-robo-advice
Section I(c) lists exclusions: the exemption does not apply where the transaction results from investment advice generated solely by an interactive website using software-based models, without personal interaction with an Investment Professional. The stipulated facts match that exclusion exactly, so the Section II conditions analysis never starts — however well the platform performs them, the exemption is unavailable for this advice channel.
Selects excluded-robo-advice; recognizes a structural exclusion defeats condition-level compliance.
“The transaction is a result of investment advice generated solely by an interactive website in which computer software-based models or applications provide investment advice”
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.
“The transaction is a result of investment advice generated solely by an interactive website in which computer software-based models or applications provide investment advice based on personal information each investor supplies through the website, without any personal interaction or advice with an Investment Professional (i.e., robo-advice)” — dol-pte-2020-02
The answer key correctly identifies that the scenario falls under the exclusion in Section I(c)(2) of PTE 2020-02, which explicitly states that the exemption does not apply to transactions resulting from investment advice generated solely by an interactive website using software-based models without personal interaction with an Investment Professional (robo-advice).
“The transaction is a result of investment advice generated solely by an interactive website in which computer software-based models or applications provide investment advice based on personal information each investor supplies through the website, without any personal interaction or advice with an Investment Professional (i.e., robo-advice)” — dol-pte-2020-02
The key correctly identifies that PTE 2020-02 Section I(c)(2) excludes transactions resulting from robo-advice generated solely by an interactive website without personal interaction with an Investment Professional. The stipulated facts match exactly: no Investment Professional interacts or reviews, and the advice is generated entirely by software from online investor input. Therefore the platform cannot rely on PTE 2020-02, regardless of satisfying Section II conditions.
v1; no errata. Demonstrate a key error and the correction is published here, credited — challenge policy.