• Evaluation of the processes that firms have used to identify and address conflicts of interest related to recommendations.
• Continued evaluation of firms’ policies and procedures with regard to Reg BI compliance.
The SEC Examinations Division said it is encouraging firms to continue to evaluate their processes and, in particular, to consider whether the initial programs they adopted by the June 30 compliance date are reasonably designed to achieve compliance with Regulation BI.
Until now, SEC examiners have focused on assessing whether firms have made a good-faith effort to comply with Reg BI.
Broker-Dealers can send questions about Reg BI and exams to the SEC’s Inter-Divisional Standards of Conduct Implementation Committee at [email protected].