It was great to be back at the FINRA Annual Conference, reconnecting with industry colleagues and making connections with new faces. The conversations picked up right where they should: what firms are seeing in the field, where the process still gets messy, and how teams are continuing to improve their Reg BI and rollover workflows.

One thing that stood out: the session on Regulation Best Interest and Form CRS in Practice was full. That says a lot. Reg BI and Form CRS have been in place for six years, but firms are still actively working through how to operationalize them as products, platforms, technology, and client expectations continue to evolve.

The session reinforced that Reg BI is not a static compliance requirement. It is a living framework.

A major focus was on new product onboarding. The panel emphasized that Reg BI begins before a recommendation is ever made. It starts when a firm decides whether a product belongs on the shelf. Firms need to ask: who is this product for, what client need does it fill, how does it compare to alternatives, what conflicts does it create, and how will advisors be trained?

The panel also stressed that product approval should not be a one-time event. Firms should revisit products after launch to confirm they are being used as expected, remain aligned with the intended client profile, and do not create new or unmanaged risks.

Another key theme was documentation. The panel drew a clear line between describing a product and documenting why it is in a specific client’s best interest. Saying that a product offers downside protection, income, or a buffer may explain the feature, but it does not explain the recommendation. The file should show why that feature matters to the client, what alternatives were considered, how cost was evaluated, and why the recommendation makes sense.

That point is especially important for complex or higher-cost products. Even firms that view themselves as “plain vanilla” may now encounter complexity through interval funds, private credit exposure, annuities, structured products, leveraged ETFs, or securities-backed lending. These products require strong due diligence, targeted training, clear procedures, and effective post-sale supervision.

Technology and AI were also part of the discussion. One example involved using AI to review advisor notes and prompt representatives when their rationale is too product-focused. Smaller firms are also using AI to summarize guidance, build training materials, and analyze activity reports. The message from the panel was balanced: AI can improve efficiency and consistency, but firms remain responsible for governance, supervision, and outcomes.

The session also touched on exams. FINRA’s Reg BI exams have become more targeted and risk-based. Firms were encouraged to engage examiners early, explain their business model, and have practical conversations about data requests and documentation processes.

The broader takeaway from the conference was clear: Reg BI is still very much an active priority. The firms best positioned for success will be those that keep connecting product governance, advisor training, documentation, supervision, technology, and disclosure management back to one core question: Why is this recommendation in the client’s best interest?