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advisor or adviser in marketing materials, disclosures, customer agreements, websites, on business cards or on social media while operating in the capacity of a BD’s RR (not as an IA); 13 32 percent of BDs that allowed RRs to use the title had no prerequisite for the RRs’ use of that title ( e.g., requiring the RR to be dually registered as both an RR and IA representative). 14 38 percent of BDs surveyed did not have E&O insurance to cover investor losses. 15 16 2. Reg BI Survey, Phase Two & Examinations, 2021 The Committee plans to conduct Phase Two of the Reg BI Survey this summer, and also expects that the States will begin to conduct Reg BI examinations (both remotely, and onsite); those exams may include the Reg BI Survey or occur independent of the Reg BI Survey. It appears that originally, the Committee planned to gather the Phase Two survey results and then roll-out the Reg BI examination modules to the States – more on modules below – but as we all know by

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