FINRA published observations from Regulation Best Interest examinations, sharing common deficiencies and best practices to help member firms improve their Reg BI compliance programs.
Common deficiencies identified include inadequate documentation of the care obligation analysis, inconsistent evaluation of reasonably available alternatives, and compensation structures that may incentivize higher-cost products.
Form CRS deficiencies were also noted, including failure to update disclosures after material changes, inconsistent delivery to retail customers, and boilerplate language that does not adequately describe firm-specific conflicts.
FINRA encourages firms to review their Reg BI policies and procedures against the published examination findings and address any identified gaps in documentation, supervision, and conflict mitigation.