Conflicts Of Interest

This one cuts through one of the messiest areas in financial compliance: when your compensation or firm structure creates an incentive that might not align with client interests. It covers the Reg BI mitigation hierarchy, fiduciary disclosure requirements, principal trading consent rules, soft dollar safe harbors, and pay-to-play restrictions. Use it when you're evaluating whether a recommendation involves a material conflict, designing disclosure language that's actually specific enough to pass muster, or figuring out whether revenue sharing on proprietary products needs to be disclosed, mitigated, or eliminated outright. The distinction between what you can disclose versus what you must eliminate under Reg BI is crucial and often misunderstood.