On 7 May 2020, SEC published FAQs on Reg BI on externally-executed transactions.
- Recommendations to existing retail customers must comply with Reg BI at the time they were made, even if the customer executes the transaction with a different firm.
- Reg BI inapplicable if customer executes a self-directed account, no recommendation.
- Firms may deliver disclosures under disclosure obligation in a foreign language if also delivered in English; must be complete and fair, not misleading, cannot translate SEC.
