Financial Services · Moraph software

Reg BI (Regulation Best Interest) Tracker

Record why each recommendation was in the client's best interest, when it was made

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Overview

What you are buying

The Reg BI Tracker captures each recommendation a financial professional makes, checks it against the client's investment profile, costs and reasonably available alternatives, and records the reasoning at the point of sale. Supervisors review flagged recommendations with the full context in front of them. Compliance can show how the firm met its care, disclosure, conflict of interest and compliance obligations, recommendation by recommendation.

The problem it solves

Regulation Best Interest asks broker-dealers to show that each recommendation to a retail customer was made in that customer's best interest, considering costs and reasonably available alternatives. In many firms the evidence is scattered: the client profile lives in the CRM, the recommendation in the order system, the rationale in a note field or nowhere, and the Form CRS delivery record somewhere else. Supervisors review exceptions without context, and when an examiner asks why a particular product was recommended, the answer depends on what the representative remembers.

  • Recommendation rationale is rarely captured when the recommendation is made
  • Client profiles, products and costs sit in different systems
  • Supervisory reviews lack the alternatives and costs that were considered
  • Form CRS delivery and conflict disclosures are hard to evidence per client

Who uses it

  • Broker-dealers and dual registrants serving retail customers
  • Financial professionals who make recommendations to clients
  • Branch and OSJ supervisors who review recommendations
  • Chief compliance officers and compliance testing teams
  • Internal audit and examiners, who need evidence of each recommendation

Requirements it supports

SEC Regulation Best Interest (17 CFR 240.15l-1)SEC Form CRS Relationship Summary (17 CFR 240.17a-14)SEC Rules 17a-3 and 17a-4 (broker-dealer books and records)FINRA Rule 3110 (Supervision)FINRA Rule 2111 (Suitability)NAIC Suitability in Annuity Transactions Model Regulation (#275)

The product supports these requirements; meeting them remains your organization’s responsibility.

See how it works

A short walkthrough

Illustrative screens with fictional sample data. They show the workflow, not any client’s data or configuration, and the layout of the product itself differs. A live demonstration uses the product with sample data.

  1. Step 1

    Recording a recommendation

    The representative records the recommendation with the client's profile, the alternatives and costs in view.

    Client 40817 · Recommendation REC-66120

    Recommended product
    Example Balanced Fund, Class A (fictional)
    Amount
    $45,000
    Client objective
    Moderate growth
    Risk tolerance
    Moderate
    Time horizon
    10+ years
    Form CRS delivered
    Yes, current version

    Rationale prompts

    • Why this product fits the client's objectives
    • Why this share class, given expected holding period
    • Which alternatives were considered and why not chosen
    • Conflicts disclosed to the client
    The representative records the recommendation with the client's profile, the alternatives and costs in view.

  2. Step 2

    Alternatives and costs

    Reasonably available alternatives from the firm's shelf appear with their costs, and the ones considered are recorded.

    ProductShare classUpfront chargeAnnual costConsidered
    Example Balanced Fund (fictional)Class ASample rate ASample rate BRecommended
    Example Balanced Fund (fictional)Class CNoneSample rate CYes
    Example Index Portfolio (fictional)AdvisoryNoneSample rate DYes
    Example Target Date Fund (fictional)Class ASample rate ESample rate FNo
    Reasonably available alternatives from the firm's shelf appear with their costs, and the ones considered are recorded.

  3. Step 3

    The supervisory queue

    Supervisors see flagged recommendations for their representatives, with the reason each was flagged.

    RecommendationRepresentativeProduct typeFlagAgeStatus
    REC-66120Rep 2041Mutual fundShare class vs holding period1 dayNew
    REC-66104Rep 1187Variable annuityComplex product2 daysNew
    REC-66097Rep 2041RolloverRetirement plan rollover2 daysInfo requested
    REC-66083Rep 3302EquityConcentration above firm limit3 daysIn review
    Supervisors see flagged recommendations for their representatives, with the reason each was flagged.

  4. Step 4

    A rollover review

    Rollover recommendations carry the comparison of the existing plan and the proposed account.

    Client 39952 · Retirement plan rollover

    Existing plan
    Example Employer Plan (fictional)
    Proposed account
    IRA, advisory
    Costs compared
    Recorded
    Investment options compared
    Recorded
    Services compared
    Recorded

    Supervisor notes

    • !Rationale does not address leaving assets in the plan
    • Requested more information from the representative
    • Representative response pending
    Rollover recommendations carry the comparison of the existing plan and the proposed account.

  5. Step 5

    Review history

    Each recommendation keeps the full history of who recorded, reviewed and decided what.

    REC-66097 · History

    1. Recommendation recorded with rationaleRepresentative
    2. Flagged: retirement plan rolloverFirm rule
    3. More information requested on plan comparisonSupervisor
    4. Comparison of staying in plan addedRepresentative
    5. Approved with noteSupervisor
    Each recommendation keeps the full history of who recorded, reviewed and decided what.

  6. Step 6

    Recommendation patterns

    Compliance looks across representatives and products to find patterns that need a closer look.

    BranchRecommendationsComplex productsRolloversFlagsOpen findings
    Branch 12 (fictional)4182231471
    Branch 07 (fictional)3765819633
    Branch 21 (fictional)2901444390
    Branch 03 (fictional)205912180
    Compliance looks across representatives and products to find patterns that need a closer look.

Workflows

The principal workflows

  1. Profile

    Each client's investment profile is brought together from your CRM and account systems, so recommendations are checked against current information.

    • Client profile data arrives from CRM, account opening and suitability forms
    • Missing or outdated profile items are flagged before a recommendation
    • Representative confirms or updates the profile with the client
    • Profile changes recorded with date and source
    • Form CRS delivery recorded against the client

  2. Recommend

    When a representative makes a recommendation, the Tracker records the product, the alternatives considered, the costs and the rationale, and runs the firm's checks.

    • Recommendation captured from the order system or entered by the representative
    • Firm rules check the product against the client's profile, concentration and costs
    • Reasonably available alternatives from your product shelf shown for comparison
    • Representative records the rationale and any conflicts disclosed
    • Recommendation submitted, with flagged items sent for supervisory review

  3. Supervise

    Supervisors work a queue of flagged recommendations with the profile, alternatives, costs and rationale on one screen, and record their decision.

    • Queue sorted by flag, product type and age
    • Supervisor reviews the recommendation, alternatives and rationale
    • Supervisor approves, requests more information or escalates
    • Follow-up with the representative recorded on the recommendation
    • Escalations go to compliance with the full record attached

  4. Test and evidence

    Compliance tests samples of recommendations, tracks patterns across representatives and products, and produces evidence for examiners.

    • Samples drawn by product, representative, branch or flag
    • Tester records whether the rationale and checks were adequate
    • Patterns such as repeated rollovers or high-cost share classes reviewed
    • Findings tracked to resolution
    • Evidence packages exported for internal audit and examiners

Roles and permissions

Who does what in the product

Each role below is a starting point. During implementation we set them up to match your teams, and every action anyone takes is recorded in the audit trail.

Financial professional

Registered representative, financial advisor, dual-registered advisor

Makes recommendations to retail clients and records why each one is in the client's best interest.

Sees

  • Their own clients' profiles and Form CRS delivery status
  • Products on the shelf with costs and alternatives
  • Their recommendations and the outcome of any review
  • Requests for more information from their supervisor

Does

  • Records recommendations, alternatives considered and rationale
  • Confirms or updates client profile information with the client
  • Records disclosures made to the client
  • Responds to supervisor questions on flagged recommendations
  • Records Form CRS delivery where not captured automatically

Cannot

  • Approve their own flagged recommendations
  • See other representatives' clients unless your firm assigns shared books
  • Change firm rules, product costs or alternatives
Approvals
Recommendations flagged by firm rules are reviewed by their supervisor before or after the trade, as your procedures set.
Notified about
Flags on their recommendations, client profiles needing an update, and supervisor requests for information.

Supervisor

Branch manager, OSJ principal, registered principal

Reviews flagged recommendations for the representatives they supervise and records each decision.

Sees

  • Flagged recommendations from their representatives
  • Client profile, alternatives, costs and rationale for each
  • Their representatives' recommendation history and patterns

Does

  • Approves flagged recommendations with a note
  • Requests more information from the representative
  • Escalates recommendations to compliance
  • Records follow-up actions with representatives
  • Reviews patterns for their branch

Cannot

  • Review recommendations they made themselves as a producing supervisor
  • Change firm rules or product data
  • Close compliance findings
Approvals
Their decisions are subject to compliance testing; escalations are decided by compliance. Their own recommendations are reviewed by another principal.
Notified about
New flagged recommendations, responses from representatives, and reviews approaching the age your procedures set.

Compliance officer

Chief compliance officer, Reg BI program owner, compliance manager

Owns the firm's Reg BI program: sets rules, decides escalations and answers to examiners.

Sees

  • All recommendations, reviews and escalations
  • Firm rules and their change history
  • Testing findings and pattern reports
  • The full audit trail

Does

  • Approves changes to firm rules and thresholds
  • Decides escalated recommendations
  • Maintains the conflicts register and mitigations
  • Assigns testing and closes findings
  • Prepares exam and management reporting

Cannot

  • Edit or delete entries in the audit trail
  • Alter a recommendation's recorded rationale
  • Apply a rule change without a recorded approval
Approvals
Approves rule changes and decides escalations; rule changes they propose themselves need a second compliance approver.
Notified about
Escalations, rule change requests, overdue supervisory reviews and new testing findings.

Compliance tester

Compliance testing analyst, surveillance analyst, compliance QA

Tests samples of recommendations and supervisory decisions so the firm can show its program works.

Sees

  • Recommendations and supervisory decisions in the samples drawn
  • Pattern reports by representative, product and branch
  • Findings and their status

Does

  • Draws samples by product, representative, branch or flag
  • Records whether each recommendation and review was adequate
  • Raises findings and tracks them to resolution
  • Reviews patterns such as rollovers and high-cost share classes

Cannot

  • Change the original recommendation or supervisory decision
  • Close their own findings
  • Change firm rules
Approvals
Findings are reviewed and closed by the compliance officer.
Notified about
New samples, responses to findings and findings approaching their target date.

Product and due diligence

Product due diligence analyst, product manager, investment research

Keeps the product shelf, costs and alternatives accurate, since recommendations are checked against them.

Sees

  • Products, share classes, costs and features
  • Which products are grouped as alternatives to each other
  • How often each product is recommended

Does

  • Maintains product and cost data
  • Defines reasonably available alternatives
  • Marks complex or higher-risk products for additional review
  • Records product due diligence outcomes

Cannot

  • See individual client profiles
  • Review or approve recommendations
  • Change firm rules
Approvals
Changes to complex product designations and alternative groupings are approved by compliance.
Notified about
Cost data that is missing or out of date, and approvals of their changes.

Auditor or examiner (read-only)

Internal auditor, external auditor, regulatory examiner (under temporary access)

Reviews recommendations, supervisory decisions and evidence without being able to change anything.

Sees

  • Recommendations and reviews within the scope granted
  • Firm rules, testing results and conflicts register
  • The audit trail

Does

  • Searches and reads records within their scope
  • Exports records they have been given access to, with each export logged
  • Leaves review notes where the firm enables them

Cannot

  • Change, approve or delete anything
  • See records outside the scope and dates granted
  • Keep access after it expires
Approvals
Their access is approved by the compliance officer or an administrator, with a scope and an end date.
Notified about
Nothing by default; access granted and expiring is confirmed to the person who approved it.

Administrator

Application administrator, compliance systems administrator

Manages users, supervisory hierarchy and integrations without access to client recommendations.

Sees

  • Users, roles and the supervisory hierarchy
  • Integration status and errors
  • The record of permission changes

Does

  • Adds and removes users, or maps them from single sign-on groups
  • Maintains which supervisor reviews which representatives
  • Monitors integrations with CRM and order systems
  • Runs access review reports

Cannot

  • Open client profiles or recommendations
  • Grant themselves a supervisory or compliance role without approval
  • Change firm rules
Approvals
Changes to the supervisory hierarchy are approved by compliance.
Notified about
Integration failures, representatives without an assigned supervisor and access reviews coming due.

Permissions at a glance

ActionProfessionalSupervisorComplianceTesterProduct teamAuditorAdmin
Record a recommendation and rationaleOwn work onlyOwn work onlyNo accessNo accessNo accessNo accessNo access
Update client profilesOwn work onlyView onlyView onlyView onlyNo accessView onlyNo access
Review flagged recommendationsNo accessOwn work onlyFullView onlyNo accessView onlyNo access
Decide escalationsNo accessNo accessFullView onlyNo accessView onlyNo access
Maintain products and costsView onlyView onlyApprovesNo accessFullView onlyNo access
Define alternativesView onlyView onlyApprovesNo accessFullView onlyNo access
Change firm rules and thresholdsNo accessNo accessApprovesView onlyNo accessView onlyNo access
Record testing findingsNo accessNo accessApprovesFullNo accessView onlyNo access
Maintain conflicts registerView onlyView onlyFullView onlyNo accessView onlyNo access
View audit trailNo accessNo accessView onlyView onlyNo accessView onlyView only
Manage users and hierarchyNo accessNo accessApprovesNo accessNo accessNo accessFull
  • Full
  • Own work only
  • Approves
  • View only
  • No access

How access is controlled

  • Producing supervisors never review their own recommendations; those go to another principal, and rule changes need a second compliance approver.
  • Representatives see only their own clients unless your firm sets up shared books or teams. Roles can be renamed, custom roles created and access limited by branch, region or business line during implementation.
  • Every permission and hierarchy change is recorded in the audit trail, and access review reports list each person's roles for periodic certification by compliance.
  • Staff sign in through your identity provider, and roles can follow its groups. Auditors and examiners get temporary read-only access with a defined scope and an end date.

Features

What it does

Point-of-sale rationale

Representatives record why a recommendation is in the client's best interest while making it, using prompts your firm configures.

Profile checks

Recommendations are checked against the client's investment profile, including objectives, risk tolerance, time horizon and liquidity needs.

Alternatives comparison

Reasonably available alternatives from your product shelf shown with their costs and features, and the ones considered recorded.

Cost visibility

Fees, commissions, share class and other costs for the recommended product and its alternatives shown side by side.

Rollover and account-type reviews

Recommendations to roll over retirement assets or change account type capture the comparison and reasoning those decisions need.

Configurable firm rules

Your firm's thresholds for concentration, complex products, costs and frequency of trading are set as rules, with each change recorded.

Supervisory queue

Flagged recommendations routed to the right supervisor with everything needed to decide, and decisions recorded with a reason.

Disclosure records

Form CRS delivery and conflict of interest disclosures recorded per client, with the version delivered.

Conflicts register

Conflicts identified by the firm recorded with their mitigation, and linked to the recommendations they affect.

Compliance testing

Sample recommendations for review, record findings and track them until they are resolved.

Pattern review

Views of recommendations by representative, product and branch to find trends such as concentration in higher-cost products.

Exam-ready audit trail

Who recommended, reviewed, approved and changed what, and when, for every recommendation.

Integrations

How it connects to your systems

Connects toHowWhat flows
CRM and client profilesClient investment profiles, account details and contact records from your CRM, including Moraph's CRM for Finance managed service.In: client profiles and account records. Out: profile update requests.
Order and trading systemsRecommended transactions captured from your order entry or trading platform so recommendations are recorded where the trade starts.In: orders with representative, client and product.
Product and cost dataProduct, share class and fee data from your product master or data vendor feeds you already license.In: products, share classes, fees and features.
Disclosure deliveryForm CRS and disclosure delivery events from your document delivery or e-signature system.In: delivery events with document version and date.
Communication archiveLinks to related client communications in your archive, so reviewers can see what was discussed.In: message references for a client and period.
Single sign-onStaff sign in through your identity provider (SAML or OpenID Connect).In: user identity and group membership for role assignment.
Work APIRecommendation, review and testing data available to your data warehouse and reporting tools through the Moraph Work API.Out: recommendations, flags, decisions and findings.

Each integration is confirmed in discovery and specified in the design. See how an engagement progresses.

Security and privacy

How your data is protected

Single sign-on

Staff sign in through your identity provider, so your password and multi-factor policies apply.

Role-based access

Representatives see their own clients, supervisors their own representatives, and reviewing is separate from recommending.

Client data protection

Client profile data is limited to the roles that need it; product and administrator roles do not see it.

Encryption and keys

Client data is encrypted, with keys Moraph staff cannot use without explicit, time-bound authorization.

Complete audit trail

Every view, recommendation, decision and change is logged with the person and time, and cannot be edited.

Data residency

Data stays in the hosting region you choose: the United States, the United Kingdom or Australia.

Company-wide controls, independent audits (SOC 2 Type II and ISO/IEC 27001) and data residency are described in our Trust Center, where you can request the evidence pack.

Reporting

What you can report on

11 standard reports, grouped by who uses them. Each shows who it is for, how it can be broken down, how it is delivered and what it is used for. The data behind them is also available to your own reporting tools.

Supervision

Supervisory review queue

For supervisors and compliance

Flagged recommendations waiting for review, with the flag, product, representative and age of each.

Break down by
Supervisor, Branch, Flag type, Age
Delivered as
Live dashboard; scheduled email
Used for
Making sure flagged recommendations are reviewed within your procedures.

Supervisory decisions

For compliance officer

Decisions made on flagged recommendations, how many were approved, returned or escalated, and the reasons given.

Break down by
Supervisor, Branch, Decision, Period
Delivered as
Live dashboard; CSV export
Used for
Checking that supervision is consistent across branches.

Profile currency

For supervisors and representatives

Clients whose investment profile is missing items or has not been confirmed within the period your firm sets.

Break down by
Representative, Branch, Missing item
Delivered as
Live view; scheduled email
Used for
Keeping profiles current so recommendations are checked against accurate information.

Patterns

Recommendation patterns

For compliance officer and testers

Recommendations by product type, share class, cost band and representative, compared across the firm.

Break down by
Representative, Product type, Share class, Branch, Period
Delivered as
Live dashboard; CSV export
Used for
Finding concentrations in higher-cost or complex products that need a closer look.

Rollovers and account-type changes

For compliance officer and supervisors

Rollover and account-type recommendations with the comparison and rationale recorded for each.

Break down by
Representative, Source account type, Destination, Period
Delivered as
Live view; CSV and PDF export
Used for
Reviewing a category of recommendation that examiners commonly focus on.

Rule flags

For compliance officer

How often each firm rule flagged a recommendation and what happened to the flagged items.

Break down by
Rule, Outcome, Branch, Period
Delivered as
Live dashboard; CSV export
Used for
Tuning rules that flag too much or too little.

Regulatory and audit

Form CRS delivery

For compliance officer and examiners

Form CRS delivery for each retail client, with the version and date, and clients without a recorded delivery.

Break down by
Representative, Version, Delivery method, Period
Delivered as
Live view; CSV and PDF export
Used for
Evidencing the disclosure obligation and finding gaps.

Rule change history

For compliance officer and examiners

Every change to firm rules and thresholds with who proposed and approved it and when it took effect.

Break down by
Rule, Change date, Approver
Delivered as
Live view; PDF and CSV export
Used for
Showing how the firm's controls have been maintained.

Recommendation record

For internal audit and examiners

For a selected recommendation, the client profile at the time, alternatives and costs shown, rationale, disclosures and every review.

Break down by
Client, Representative, Date range
Delivered as
On request in the product; PDF export
Used for
Answering an examiner's question about a specific recommendation.

Testing

Testing findings

For compliance officer and testers

Findings from compliance testing, their severity as your firm grades it, owner and status.

Break down by
Finding type, Branch, Owner, Status
Delivered as
Live dashboard; CSV export
Used for
Tracking findings to resolution and reporting on program effectiveness.

Conflicts and mitigations

For compliance officer and senior management

Conflicts of interest identified by the firm, their mitigation and the recommendations they affected.

Break down by
Conflict type, Product, Period
Delivered as
Live view; PDF export
Used for
Evidencing the conflict of interest obligation and its annual review.

Exports, access and evidence

  • Every report can be exported to CSV, and summary and evidence reports to PDF. Reports can be scheduled to arrive by email for the people entitled to see them.
  • Filters can be saved, so a supervisor, tester or the compliance officer can keep their own views.
  • Recommendation, review and testing data is available through the Moraph Work API, and can be delivered to your data warehouse or business intelligence tool.
  • Reports respect each viewer's role: representatives see their own clients, supervisors their own branch, and examiners only what they have been granted.
  • Each recommendation record shows the client profile and product data as they stood when the recommendation was made, and gives the same result each time it is run.

Deployment

Where and how it runs

Moraph cloud

Hosted and operated by Moraph in the United States region. United Kingdom and Australia regions are available for firms that need them.

Dedicated environment

A single-tenant environment for firms whose policies require isolation, scoped in the proposal.

Embedded in advisor tools

Recommendation capture can be launched from your CRM or order entry screens so representatives do not switch systems.

Security controls, independent audits and data residency are set out in our Trust Center. Engagement models and what drives a quotation are on Working with Moraph.

Implementation

What a rollout involves

The general phases are on Working with Moraph. For this product, they involve the following.

Program review

We review your written supervisory procedures and Reg BI policies with compliance and agree how they translate into rules, prompts and review steps.

Data mapping

Client profile, account, order and product data are mapped from your CRM, trading and product systems, and the delivery schedule agreed.

Rules and prompts

Firm rules, thresholds and rationale prompts are configured for your product shelf and client base, and tested on past recommendations.

Supervisory hierarchy

Who reviews whom is configured from your supervisory structure, including producing supervisors and their reviewers.

Pilot

A pilot with selected branches checks that prompts are workable for representatives and that flags are useful for supervisors.

Training and rollout

Representatives, supervisors and compliance are trained on their own workflows, and branches are brought on in the order you choose.

Limitations

What it does not do

Worth knowing before you evaluate it.

  • The Tracker does not decide whether a recommendation is in the client's best interest. Representatives, supervisors and compliance make that judgment; the Tracker records it and the evidence.
  • Checks depend on the completeness of client profile, product and cost data supplied from your systems.
  • It does not produce or file Form CRS. It records delivery of the version your firm has prepared.
  • It does not cover investment adviser fiduciary obligations under the Advisers Act on its own, although dual registrants can record advisory recommendations in it.
  • It is designed for US broker-dealer requirements. Suitability rules in other countries are not included.
  • It is not an order management system and does not block trades; flags are routed for review according to your procedures.
  • Firm rules and thresholds are your firm's decisions; the Tracker records and applies them but does not set them.
  • Product and cost data from third-party vendors is subject to your own licences with those vendors.

Evaluation checklist

What to test in a demonstration or pilot

Questions worth putting to us, and to any other vendor you are considering.

  1. Ask a representative to record a typical recommendation and note how long the prompts take
  2. Check that the alternatives and costs shown match your product shelf
  3. Run past recommendations through your firm rules and review what is flagged
  4. Walk a flagged rollover from recommendation to supervisory decision
  5. Pull the recommendation record for a sample client and judge whether it would satisfy an examiner
  6. Confirm role separation: producing supervisors cannot review their own recommendations

Questions

Frequently asked questions

Does the Tracker slow down representatives?

Prompts are configured with your firm and tested in a pilot, so representatives record what your procedures require and no more. Capture can be launched from your CRM or order entry screens.

Can it be used for annuities and advisory accounts?

Yes. Recommendations for annuities, brokerage and advisory accounts can be recorded, with rules and prompts configured for each, including the NAIC model regulation where your state has adopted it.

Who owns the data in the Tracker?

Your firm does. How it is returned to you and deleted at the end of the agreement is set out in the contract.

How do examiners see our work?

A read-only examiner role shows recommendations, reviews, rules and testing results within the scope you grant, and everything can be exported.

How is it priced?

As a subscription, usually measured by the number of financial professionals, with implementation charged separately. See Working with Moraph for what drives a quotation.

Is there an accessibility conformance report?

Ask for one through the procurement request form at /how-to-buy/request, naming the version you are evaluating.

Next steps

Evaluate Reg BI (Regulation Best Interest) Tracker

Book a demonstration

See the product working with sample data, focused on your workflows.

Request a demonstration

Request a technical briefing

Architecture, integrations, security and hosting, with our engineers and your technical team.

Request a briefing

Factsheet

This page on two sides, to share with colleagues or add to your evaluation file.

Open the factsheet

Buying through a formal procurement? See How to buy for purchasing routes, accessibility conformance reports and company information. Documentation: Reg BI (Regulation Best Interest) Tracker guides on docs.moraph.com (getting started and security guides are public; setup, administration and integration guides are for client accounts). Support: Reg BI (Regulation Best Interest) Tracker support guide.

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