Reg BI Care Obligation Audit Data Checklist
The Reg BI Care Obligation examination focuses on whether the firm's recommendation process produces suitable recommendations for individual clients. The examiner walks through specific cases asking three questions for each: did the firm have the data to evaluate suitability, did the firm's process actually use that data, and is the audit trail of the process documented? This checklist covers the data side — every field, document, and event you should have structurally captured before the examiner arrives.
Client demographic and household data
- Member ages and roles
Age of every household member with role tagging (primary earner, spouse, dependent, ward). Required for senior-suitability triggers and POA-eligibility checks.
members[].age, members[].role - Cognitive status markers
Per FINRA Rule 2090 KYC and FINRA Notice 21-09 senior-client guidance, structured cognitive-status flags for clients age 65+. Values: none / mild / moderate / impaired.
members[].cognitive_status - Power of Attorney status
POA-on-file boolean plus most-recent-update date. Outdated POAs (>3 years) are a heightened-supervision flag for senior clients.
legal.poa_on_file, legal.poa_last_updated - Trusted contact designation
Per FINRA Rule 4512(a)(1)(F), trusted contact must be solicited from clients age 65+. Document either the contact's identity or the client's documented refusal to provide one.
legal.trusted_contact
Risk and suitability profile
- Risk tolerance score
Numerical risk-tolerance score on a documented scale (typically 1-10). Score must reconcile with the questionnaire response, not be advisor-overridden without supervisory documentation.
risk_profile.tolerance_score, risk_profile.questionnaire_responses - Investment objectives
Structured objectives ranked by priority: capital preservation, income, growth, speculation. Multiple objectives allowed but priority must be explicit.
risk_profile.investment_objectives[] - Liquidity needs
Documented liquidity requirements including time horizon for major-expense events (home purchase, education funding, retirement bridge).
risk_profile.liquidity_needs - Investment experience
Categorical investment experience (none, limited, moderate, extensive) by product class. Drives suitability for complex / illiquid products.
risk_profile.investment_experience
Account and concentration data
- Holdings detail per account
Lot-level holdings with cost basis, current value, and asset-class classification. Aggregated views are insufficient for concentration analysis.
accounts[].lots[].symbol, .cost_basis, .current_value - Concentration percentage
Pre-computed single-position concentration as a percentage of liquid assets. Concentration > 25% is a Reg BI red flag for the canonical fact pattern.
assets.concentration_pct - Cross-account holding view
Holdings rolled up across all accounts in the household graph (taxable, tax-deferred, spouse accounts). Required to detect cross-account concentration the single-account view misses.
assets.household_total_concentration
Recommendation and audit trail
- Recommendation history
Trailing 24+ months of recommendations with timestamp, recommended product, rationale, and the supervisory disposition. This is the core audit-trail artifact.
recommendations[] - Supervisory disposition per recommendation
For each recommendation, the supervisory action: approved / rejected / approved-with-conditions / referred-for-Series-24-review. Series 24 review is required for senior-client high-risk recommendations.
recommendations[].supervisory_disposition - Conflict-of-interest disclosure timestamps
Form CRS and any product-specific conflict disclosures with the client's acknowledgment timestamps. Required for the Disclosure Obligation arm of Reg BI.
compliance.disclosure_acknowledgments[] - Best-interest-rationale documentation
For each recommendation, the structured rationale explaining why this recommendation is in the client's best interest — not just suitable. This is the core Care Obligation artifact.
recommendations[].best_interest_rationale
Event and trigger flags
- Recent-inheritance flag
Boolean flag for inheritance events within 18 months. Pairs with subsequent recommendations to detect the recent-wealth + illiquid-product fact pattern.
events.recent_inheritance, events.inheritance_date - Suitability mismatch flags
Pre-computed flags where account allocation exceeds risk tolerance. The supervisory engine should fire on these; absence of firing is a process-failure signal.
compliance.suitability_flags[] - Heightened supervision triggers
Categorical triggers per FINRA Rule 4512 for senior clients, post-divorce, recent-loss, cognitive-decline. Each trigger drives specific supervisory protocols.
compliance.heightened_supervision_triggers[]
Key takeaways
- The examination focuses on whether the firm's process used the data — having the data structured but not consumed by the supervisory engine is itself a finding.
- FINRA Rule 4512(a)(1)(F) trusted contact solicitation for clients 65+ is a frequently-cited gap; document the solicitation outcome (contact provided or refused).
- Cross-account concentration (across taxable + tax-deferred + spouse) is required — single-account concentration misses the most common Reg BI red flag.
- Audit trail is the artifact: best-interest rationale per recommendation, supervisory disposition per recommendation, disclosure acknowledgment timestamps. Without these, the examination has nothing to evaluate.