Independent Broker Dealer Consortium

Bates Compliance’s Reg BI Countdown Kick-Off Begins!

October is here! That means the SEC’s Reg BI implementation deadline is right around the corner. To support your implementation efforts, Bates Compliance is rolling out the Bates Reg BI Countdown with action items to keep your compliance team on track as the June 30, 2020 implementation deadline approaches.

The Bates Compliance consulting team, made up of former CCOs and senior regulators, will be providing you with ongoing insight and deadline reminders as the implementation date approaches. Our goal is to make the implementation process easy for you and to encourage the participation of your entire team.

Action Item 1: Take Steps to Review Conflicts

Here are three easy steps to review potential conflicts of interest:

  1. Assemble representatives from various internal groups of your firm
  2. Appoint an individual to be the conflicts coordinator and/or a designated conflicts lead.
  3. Identify and start documenting your firm’s conflicts and mitigation controls.

Where can you find conflicts?

According to Bates Compliance Director Jill Ehret, high-level conflicts of interest can include:

  • Compensation payouts
  • Products offered by the firm
  • Outside Business Activities
  • Individual Conflicts
  • Investment Advisory and other financial services affiliations
  • Ownership structure of the firm

Now that you have an initial plan, you can roll up your sleeves and get to work! But just in case you need a little extra support, Bates is here to help. Bates Compliance helps firms with their Reg BI implementation, including further defining conflicts, determining your disclosure approach and mitigating risk to your firm.

Want to learn more? Please call or email Bates Managing Director Bob Lavigne at (508) 868-6741 or

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