Care obligation framing
Regulation Best Interest requires broker-dealers and associated persons to act in the retail customer’s best interest without placing the firm’s financial interest ahead of the customer’s. RIAs remain subject to the Investment Advisers Act fiduciary standard. Investment migration sits adjacent to securities when offerings are marketed alongside residence benefits; your CCO should classify each arrangement.
Disclosure of conflicts
Capture referral fees, soft dollars, conference sponsorships, and equity ties to promoters. If the advisor cannot state conflicts with specificity, pause the introduction until the broker or promoter delivers written economics suitable for the client file.
Reasonable alternatives
Comparable programs (jurisdiction, capital type, liquidity, timeline) should appear in the memo, including “do nothing” or deferral if processing backlogs or rule changes undermine suitability. Generic brochures rarely satisfy examiners looking for individualized rationale.
Record retention
Retain emails, comparison grids, meeting notes, and signed acknowledgments in the same system as traditional securities recommendations. Cross-border engagements often face longer lookback periods in arbitration; patchwork storage is a common exam finding.
Related reading
Advisor Resources: Using the platform · CBI source of funds for trusts