Drafting comprehensive Suitability and Regulation Best Interest policies requires deep regulatory knowledge, careful attention to FINRA Rule 2111 and SEC requirements, and hours of manual document preparation. Compliance officers must balance multiple obligations—reasonable-basis suitability, customer-specific analysis, quantitative suitability, and the four core Reg BI obligations—while ensuring every provision meets current regulatory standards.
Broker-dealers face complex, overlapping obligations under Regulation Best Interest and FINRA Rule 2111, requiring comprehensive policies that address disclosure, care, conflict management, and suitability standards. Manually drafting these policies requires extensive regulatory research, legal expertise, and 20+ hours of attorney time, costing firms $8,000-$15,000 while risking gaps in coverage that could lead to regulatory deficiencies.
CaseMark generates complete, board-ready Suitability and Best Interest policies tailored to your firm's business model, products, and compensation structures. Upload your existing compliance materials and receive a comprehensive policy document covering all Reg BI obligations, FINRA suitability requirements, Form CRS integration, and enforcement procedures—ready for immediate implementation.
This workflow is applicable across multiple practice areas and use cases
Securities firms need comprehensive governance policies that include Reg BI compliance frameworks as part of their board-level oversight and corporate compliance structure.
Corporate governance for broker-dealers and securities firms requires documented policies on fiduciary obligations and best interest standards, which are core governance responsibilities overseen by boards and compliance committees.
M&A due diligence requires reviewing target broker-dealer compliance policies including Reg BI and suitability frameworks to assess regulatory risk and compliance posture.
Acquiring or merging with broker-dealers necessitates comprehensive review of regulatory compliance infrastructure, and this workflow helps structure compliant policies post-transaction or identify gaps during diligence.
Securities litigation and customer disputes require analysis of broker-dealer compliance policies to establish whether firms met their best interest and suitability obligations under Reg BI.
Plaintiff and defense attorneys in securities disputes need to evaluate existing compliance policies against regulatory standards to prove or defend claims of unsuitable recommendations or best interest violations.
New broker-dealer formations or RIA conversions require establishing comprehensive Reg BI compliance policies from inception to meet FINRA registration and operational requirements.
Forming a new securities firm requires complete compliance infrastructure including Reg BI policies before commencing operations, making this workflow essential for startup broker-dealers and investment advisers.
FINRA Rule 2111 requires that recommendations be suitable based on customer information, while Regulation Best Interest imposes a higher standard requiring broker-dealers to act in the retail customer's best interest. Reg BI includes four specific obligations—disclosure, care, conflict of interest, and compliance—that go beyond traditional suitability by requiring consideration of reasonably available alternatives, enhanced conflict management, and comprehensive disclosures. This policy addresses both frameworks to ensure complete compliance.
CaseMark can generate a comprehensive Reg BI policy without any uploads, providing a complete framework based on current regulatory requirements. However, uploading optional documents like your existing compliance manual, product lists, or compensation structures allows CaseMark to customize the policy to your firm's specific business model, making it immediately implementable rather than requiring extensive post-generation editing.
The generated policy includes a dedicated section on Form CRS integration, covering delivery requirements, required content, formatting specifications, and amendment procedures. It explains how Form CRS provides high-level relationship disclosures while the Reg BI Disclosure Obligation requires more detailed, recommendation-specific information. The policy ensures your firm understands both the summary disclosures in Form CRS and the comprehensive disclosures required for each recommendation.
Yes, the policy is designed to demonstrate compliance during regulatory examinations by addressing all required elements of Reg BI and FINRA Rule 2111, including written policies and procedures, supervisory systems, training requirements, and documentation standards. It includes specific procedures for reasonable-basis determinations, customer-specific suitability analysis, conflict identification and mitigation, and recordkeeping—all areas examiners routinely review. The policy provides the written framework examiners expect to see as evidence of a reasonably designed compliance program.
The generated policy includes provisions for periodic review and updating, typically annually or when material changes occur to your business model, product offerings, compensation structures, or regulatory requirements. You should review the policy whenever SEC or FINRA issues new guidance on Reg BI or suitability, when examination findings reveal gaps, or when your firm introduces new products or services. CaseMark can regenerate updated versions as regulations evolve or your firm's practices change.