Yesterday, the newly re-named Division of Examination (formerly known as OCIE)  at the SEC released a statement noting that they intend to expand the scope of Reg BI examinations in 2021 to go beyond "good faith efforts" to comply and focus on the specific requirements of the rule, including: alterations to the product shelf, consideration of costs in making a recommendation, rollovers, complex products and reasonably available alternatives, and processes to identify and address conflicts. This is line with our past expectations that beginning in 2021 the SEC exam program would look beyond good faith compliance with the rule.