Reg BI Care Obligation Evidence-Field Worksheet
An SEC examiner walking a Reg BI Care Obligation exam asks a structured set of questions per recommendation type. This worksheet flips that around: list the firm's recommendation types up front, capture the evidence the examiner will ask for, and surface the gaps before they're a finding. Pairs cleanly with the Reg BI Audit Data Checklist.
What you walk away with
~20 min · 4 sections · 7 fields- A per-recommendation-type evidence ledger that maps to the Reg BI checklist's field structure.
- A captured rationale for any field the firm doesn't capture — with a date for remediation.
- A single artifact compliance can hand to the WSP author or the auditor.
Firm scope
Compliance officer accountable for the evidence ledger.
Recommendation types
List every recommendation type the firm makes — the granularity should be 'rollover' / 'mutual fund switch' / 'allocation change,' not 'sell.'
What the firm calls it internally.
What audit-trail fields, timestamps, and disclosures already exist for this recommendation type?
Fields the Reg BI checklist requires that are not captured today.
What the firm calls it internally.
What audit-trail fields, timestamps, and disclosures already exist for this recommendation type?
Fields the Reg BI checklist requires that are not captured today.
What the firm calls it internally.
What audit-trail fields, timestamps, and disclosures already exist for this recommendation type?
Fields the Reg BI checklist requires that are not captured today.
Cross-cutting evidence fields
Independent of recommendation type, these fields are universally examined.
Is every relationship's KYC structurally complete per FINRA 2090?
Is the rationale for each recommendation structurally captured?
Are heightened-supervision triggers (senior, complex, large) logged?
Evidence index
Live calculation across the cross-cutting fields.
Aggregate of the three cross-cutting fields. Below 50% is a likely-finding posture; above 80% is audit-ready.
0 = Findings Likely · 1 = Findings Possible · 2 = Defensible · 3 = Audit-Ready
Close the gaps
Take the populated worksheet to the Reg BI Audit Data Checklist; for each gap, the checklist names the field structure that closes it. Use the Reg BI Audit-Readiness Scorecard to score the firm's overall posture.
Key takeaways
- Granularity matters. 'Rollover' isn't a recommendation type; '401(k) rollover to IRA' is.
- Comparative rationale is the most-cited evidence gap. The recommendation captures the suitability fields but not the comparison to the alternative.
- Volume matters for prioritization. A high-volume recommendation type with weak evidence is the next finding.
- Cross-cutting fields beat per-type fields. Fix KYC completeness once and every recommendation type benefits.
FAQ
Does this apply to RIAs?
Reg BI Care Obligation specifically applies to broker-dealers. RIAs operate under the IA fiduciary duty — but the evidence structure is the same in practice. RIAs use this worksheet to map their fiduciary evidence to a Reg-BI-style structure for hybrid-firm consistency.
What's the right cadence?
Annually plus on every new recommendation type. The recommendation-type list is the document that ages fastest — products evolve, and a new product without an evidence design is a structural gap.