id stringlengths 11 13 | task_family stringclasses 4
values | corpus_version stringclasses 1
value | prompt stringlengths 95 231 | scenario unknown | options listlengths 2 4 ⌀ | key unknown | rubric dict | sources listlengths 1 3 | version int64 1 1 |
|---|---|---|---|---|---|---|---|---|---|
fb-regbi-0001 | regbi-suitability | 2026.9 | Do the stipulated facts establish that this recommendation violates the care obligation's reasonable-basis prong quoted in this item's sources? Answer with exactly one option id. | {
"customer": "Retail customer of a broker-dealer",
"recommendation": "The associated person recommends a newly issued structured note tied to a custom equity index.",
"stipulated_facts": [
"Neither the associated person nor the firm has reviewed the note's structure, payoff formula, embedded costs, or risks.... | [
{
"id": "violates-care-reasonable-basis",
"label": "Yes — the quoted reasonable-basis prong is violated on these facts"
},
{
"id": "prong-satisfied",
"label": "No — the quoted reasonable-basis prong is satisfied on these facts"
}
] | {
"type": "derived",
"value": "violates-care-reasonable-basis",
"derivation": "The quoted prong requires the broker, in making the recommendation, to exercise reasonable diligence, care, and skill to understand the potential risks, rewards, and costs of the recommendation and to have a reasonable basis to believe... | {
"full": "Answers yes: the quoted reasonable-basis prong is violated on the stipulated facts.",
"severity": "high"
} | [
{
"corpus_id": "sec-regbi",
"section": "(a)(2)(ii)(A)",
"quote": "Understand the potential risks, rewards, and costs associated with the recommendation, and have a reasonable basis to believe that the recommendation could be in the best interest of at least some retail customers"
}
] | 1 |
fb-regbi-0002 | regbi-suitability | 2026.9 | Judged only against the obligations quoted in this item's sources, which conclusion follows about this recommendation? Answer with exactly one option id. | {
"customer": "Retail customer, age 82, retired. Documented investment profile: capital preservation objective, low risk tolerance, anticipated liquidity needs for medical expenses, two-year investment horizon.",
"recommendation": "The associated person recommends moving 85% of the customer's investable assets into... | [
{
"id": "consistent",
"label": "The recommendation is consistent with the quoted obligations"
},
{
"id": "violates-care-reasonable-basis",
"label": "It violates the care obligation's reasonable-basis prong"
},
{
"id": "violates-care-customer-specific",
"label": "It violates the care ... | {
"type": "derived",
"value": "violates-care-customer-specific",
"derivation": "The customer-specific prong requires a reasonable basis to believe the recommendation is in the best interest of this particular retail customer based on that customer's investment profile. The stipulated profile — age 82, capital pre... | {
"full": "Selects violates-care-customer-specific and anchors the mismatch to the stipulated profile.",
"severity": "high"
} | [
{
"corpus_id": "sec-regbi",
"section": "(a)(2)(ii)(B)",
"quote": "Have a reasonable basis to believe that the recommendation is in the best interest of a particular retail customer based on that retail customer's investment profile and the potential risks, rewards, and costs associated with the recommen... | 1 |
fb-regbi-0003 | regbi-suitability | 2026.9 | Judged only against the obligations quoted in this item's sources, which conclusion follows about this pattern of recommendations? Answer with exactly one option id. | {
"customer": "Retail customer with a documented moderate-growth profile and a buy-and-hold orientation.",
"recommendation_pattern": "Over eleven months, the associated person recommended 38 buy-and-sell round trips in the account.",
"stipulated_facts": [
"Each individual trade, viewed alone, matched the cust... | [
{
"id": "consistent",
"label": "The series is consistent with the quoted obligations"
},
{
"id": "violates-care-series",
"label": "It violates the care obligation's series-of-transactions prong (excessive when taken together)"
},
{
"id": "violates-care-reasonable-basis",
"label": "It... | {
"type": "derived",
"value": "violates-care-series",
"derivation": "The quoted prong addresses exactly this pattern: a series of recommended transactions, even if each is in the customer's best interest viewed in isolation, must not be excessive taken together in light of the customer's profile. A 21% annualized... | {
"full": "Selects violates-care-series; recognizes that per-trade defensibility does not cure an excessive series.",
"severity": "high"
} | [
{
"corpus_id": "sec-regbi",
"section": "(a)(2)(ii)(C)",
"quote": "series of recommended transactions, even if in the retail customer's best interest when viewed in isolation, is not excessive and is in the retail customer's best interest when taken together in light of the retail customer's investment p... | 1 |
fb-regbi-0004 | regbi-suitability | 2026.9 | Judged only against the obligations quoted in this item's sources, which conclusion follows about this recommendation? Answer with exactly one option id. | {
"customer": "Retail customer, age 34, documented profile: long-term growth objective, high risk tolerance, 25-year horizon, no near-term liquidity needs, moderate investment experience.",
"recommendation": "The associated person recommends a diversified low-cost equity index fund for the customer's retirement acc... | [
{
"id": "consistent",
"label": "The recommendation is consistent with the quoted obligations"
},
{
"id": "violates-care-reasonable-basis",
"label": "It violates the care obligation's reasonable-basis prong"
},
{
"id": "violates-care-customer-specific",
"label": "It violates the care ... | {
"type": "derived",
"value": "consistent",
"derivation": "On the stipulated facts, every quoted obligation is satisfied: the associated person personally exercised reasonable diligence, care, and skill and understands the recommendation's risks, rewards, and costs (reasonable-basis prong); the recommendation mat... | {
"full": "Selects consistent; does not invent a violation where the stipulated facts satisfy each quoted obligation.",
"severity": "medium"
} | [
{
"corpus_id": "sec-regbi",
"section": "(a)(2)(ii)(B)",
"quote": "Have a reasonable basis to believe that the recommendation is in the best interest of a particular retail customer based on that retail customer's investment profile and the potential risks, rewards, and costs associated with the recommen... | 1 |
fb-regbi-0005 | regbi-suitability | 2026.9 | Judged only against the obligations quoted in this item's sources, which conclusion follows about this recommendation? Answer with exactly one option id. | {
"customer": "Retail customer with a documented balanced-income profile.",
"recommendation": "The associated person recommends an intermediate-term bond fund that matches the customer's profile.",
"stipulated_facts": [
"The firm performed full product diligence; the fund fits the customer's documented profil... | [
{
"id": "consistent",
"label": "The recommendation is consistent with the quoted obligations"
},
{
"id": "violates-care-customer-specific",
"label": "It violates the care obligation's customer-specific prong"
},
{
"id": "violates-disclosure",
"label": "It violates the disclosure obli... | {
"type": "derived",
"value": "violates-disclosure",
"derivation": "The disclosure obligation requires that the broker, prior to or at the time of the recommendation, provide the retail customer written full and fair disclosure of the required material facts. The stipulated facts state no such disclosure was prov... | {
"full": "Selects violates-disclosure on the timing requirement in the quoted text.",
"severity": "high"
} | [
{
"corpus_id": "sec-regbi",
"section": "(a)(2)(i)",
"quote": "prior to or at the time of the recommendation, provides the retail customer, in writing, full and fair disclosure of"
}
] | 1 |
fb-regbi-0007 | regbi-suitability | 2026.9 | Judged only against the obligations quoted in this item's sources, which conclusion follows about this recommendation? Answer with exactly one option id. | {
"customer": "Retail customer, age 68, documented profile: income objective, moderate risk tolerance, ten-year horizon, adequate emergency reserves held elsewhere.",
"recommendation": "The associated person recommends a ladder of investment-grade corporate bonds maturing over two to ten years.",
"stipulated_fact... | [
{
"id": "consistent",
"label": "The recommendation is consistent with the quoted obligations"
},
{
"id": "violates-care-reasonable-basis",
"label": "It violates the care obligation's reasonable-basis prong"
},
{
"id": "violates-care-customer-specific",
"label": "It violates the care ... | {
"type": "derived",
"value": "consistent",
"derivation": "On the stipulated facts, every quoted obligation is satisfied: the associated person personally exercised reasonable diligence, care, and skill and understands the recommendation's risks, rewards, and costs (reasonable-basis prong); the recommendation mat... | {
"full": "Selects consistent; the profile-to-product match is direct.",
"severity": "medium"
} | [
{
"corpus_id": "sec-regbi",
"section": "(a)(2)(ii)(B)",
"quote": "Have a reasonable basis to believe that the recommendation is in the best interest of a particular retail customer based on that retail customer's investment profile and the potential risks, rewards, and costs associated with the recommen... | 1 |
fb-regbi-0008 | regbi-suitability | 2026.9 | Judged only against the obligations quoted in this item's sources, which conclusion follows about this recommendation? Answer with exactly one option id. | {
"customer": "Retail customer, age 41, documented profile: saving for a home purchase expected in 18 months; funds must remain accessible; low risk tolerance for these funds.",
"recommendation": "The associated person recommends placing the entire home-purchase fund into a product with a seven-year surrender-charg... | [
{
"id": "consistent",
"label": "The recommendation is consistent with the quoted obligations"
},
{
"id": "violates-care-reasonable-basis",
"label": "It violates the care obligation's reasonable-basis prong"
},
{
"id": "violates-care-customer-specific",
"label": "It violates the care ... | {
"type": "derived",
"value": "violates-care-customer-specific",
"derivation": "The quoted prong ties the required reasonable basis to this particular customer's investment profile. The stipulated profile requires the funds within 18 months; the recommended product imposes a seven-year surrender schedule starting... | {
"full": "Selects violates-care-customer-specific on the liquidity-horizon mismatch.",
"severity": "high"
} | [
{
"corpus_id": "sec-regbi",
"section": "(a)(2)(ii)(B)",
"quote": "Have a reasonable basis to believe that the recommendation is in the best interest of a particular retail customer based on that retail customer's investment profile and the potential risks, rewards, and costs associated with the recommen... | 1 |
fb-regbi-0012 | regbi-suitability | 2026.9 | Judged only against the obligations quoted in this item's sources, which conclusion follows about this pattern of recommendations? Answer with exactly one option id. | {
"customer": "Retail customer with a documented conservative income profile and no stated interest in active trading.",
"recommendation_pattern": "Over nine months, the associated person recommended 60 buy-and-sell transactions in the account.",
"stipulated_facts": [
"Each trade, viewed alone, was researched... | [
{
"id": "consistent",
"label": "The series is consistent with the quoted obligations"
},
{
"id": "violates-care-series",
"label": "It violates the care obligation's series-of-transactions prong (excessive taken together)"
},
{
"id": "violates-disclosure",
"label": "It violates the di... | {
"type": "derived",
"value": "violates-care-series",
"derivation": "The quoted prong requires that a series of recommended transactions, even if each is defensible in isolation, not be excessive taken together in light of the customer's profile. Sixty commission-paying round trips in nine months at an 18% annual... | {
"full": "Selects violates-care-series.",
"severity": "high"
} | [
{
"corpus_id": "sec-regbi",
"section": "(a)(2)(ii)(C)",
"quote": "series of recommended transactions, even if in the retail customer's best interest when viewed in isolation, is not excessive and is in the retail customer's best interest when taken together in light of the retail customer's investment p... | 1 |
fb-regbi-0014 | regbi-suitability | 2026.9 | Judged only against the obligations quoted in this item's sources, which conclusion follows about this recommendation? Answer with exactly one option id. | {
"customer": "Retail customer with a documented balanced profile.",
"recommendation": "The associated person recommends a balanced mutual fund that fits the customer's profile.",
"stipulated_facts": [
"Product diligence and profile fit are stipulated satisfied.",
"The associated person explained the rela... | [
{
"id": "consistent",
"label": "The recommendation is consistent with the quoted obligations"
},
{
"id": "violates-disclosure",
"label": "It violates the disclosure obligation — the quoted text requires disclosure in writing"
},
{
"id": "violates-care-customer-specific",
"label": "It... | {
"type": "derived",
"value": "violates-disclosure",
"derivation": "The quoted disclosure obligation requires the broker, prior to or at the time of the recommendation, to provide the retail customer full and fair disclosure in writing. A thorough oral explanation, even recorded, is not the written disclosure the... | {
"full": "Selects violates-disclosure; oral disclosure does not satisfy an in-writing requirement.",
"severity": "high"
} | [
{
"corpus_id": "sec-regbi",
"section": "(a)(2)(i)",
"quote": "prior to or at the time of the recommendation, provides the retail customer, in writing, full and fair disclosure of"
}
] | 1 |
fb-regbi-0015 | regbi-suitability | 2026.9 | Judged only against the quoted provisions of Regulation Best Interest, is the firm's arrangement consistent with the conflict-of-interest obligation? Answer with exactly one option id. | {
"person": "Retail customer of a broker-dealer",
"facts": "For the month of March, the firm runs a sales contest: the three representatives who sell the most shares of a specific proprietary closed-end fund win a resort trip. The contest is described plainly and fully in the firm's written disclosures, which every... | [
{
"id": "violates-conflict-elimination",
"label": "No — sales contests based on specific securities within a limited period must be eliminated; disclosure cannot cure them"
},
{
"id": "consistent",
"label": "Yes — a fully disclosed conflict satisfies the obligation"
},
{
"id": "violates-... | {
"type": "derived",
"value": "violates-conflict-elimination",
"derivation": "17 CFR 240.15l-1(a)(2)(iii)(D) requires the broker-dealer's policies and procedures to identify and eliminate sales contests based on the sales of specific securities within a limited period of time. Elimination is the only treatment th... | {
"full": "Selects violates-conflict-elimination, citing (a)(2)(iii)(D)'s elimination requirement.",
"severity": "high"
} | [
{
"corpus_id": "sec-regbi",
"section": "(a)(2)(iii)(D)",
"quote": "Identify and eliminate any sales contests, sales quotas, bonuses, and non-cash compensation that are based on the sales of specific securities or specific types of securities within a limited period of time."
}
] | 1 |
fb-regbi-0016 | regbi-suitability | 2026.9 | Judged only against the quoted provisions of Regulation Best Interest, does the firm's disclosure-only treatment of this representative-level incentive satisfy the conflict-of-interest obligation? Answer with exactly one option id. | {
"person": "Retail customer of a broker-dealer",
"facts": "Representatives earn 6% on the firm's affiliated structured notes and 1% on comparable third-party notes — a rep-level incentive to favor the affiliated product. The firm's written disclosure describes the differential compensation accurately and completel... | [
{
"id": "violates-conflict-mitigation",
"label": "No — conflicts creating incentives for the natural person must be mitigated, not merely disclosed"
},
{
"id": "consistent",
"label": "Yes — accurate and complete disclosure of the differential satisfies the obligation"
},
{
"id": "violate... | {
"type": "derived",
"value": "violates-conflict-mitigation",
"derivation": "17 CFR 240.15l-1(a)(2)(iii)(B) requires policies and procedures to identify AND mitigate conflicts that create an incentive for the associated natural person to place the firm's or their own interest ahead of the retail customer's. A 6%-... | {
"full": "Selects violates-conflict-mitigation, distinguishing (iii)(B) mitigation from (iii)(A) disclosure.",
"severity": "high"
} | [
{
"corpus_id": "sec-regbi",
"section": "(a)(2)(iii)(B)",
"quote": "Identify and mitigate any conflicts of interest associated with such recommendations that create an incentive for a natural person who is an associated person of a broker or dealer to place the interest of the broker, dealer, or such nat... | 1 |
fb-regbi-0018 | regbi-suitability | 2026.9 | Judged only against the quoted provisions of Regulation Best Interest, does this sequence satisfy the disclosure obligation? Answer with exactly one option id. | {
"person": "Retail customer of a broker-dealer",
"facts": "A representative recommends a variable annuity by phone at 10 a.m. and the customer authorizes the purchase on the call; the trade executes that morning. The firm's complete, accurate written disclosure of the relationship's scope, fees, and conflicts is d... | [
{
"id": "violates-disclosure-timing",
"label": "No — the written disclosure must come prior to or at the time of the recommendation"
},
{
"id": "consistent",
"label": "Yes — same-day delivery of complete written disclosure satisfies the obligation"
},
{
"id": "violates-care-customer-spec... | {
"type": "derived",
"value": "violates-disclosure-timing",
"derivation": "240.15l-1(a)(2)(i) requires the broker-dealer, prior to or at the time of the recommendation, to provide the retail customer full and fair written disclosure. Delivery at 4 p.m., after a 10 a.m. recommendation and execution, is after the t... | {
"full": "Selects violates-disclosure-timing, citing the prior-to-or-at-the-time requirement.",
"severity": "high"
} | [
{
"corpus_id": "sec-regbi",
"section": "(a)(2)(i)",
"quote": "prior to or at the time of the recommendation, provides the retail customer, in writing, full and fair disclosure of"
}
] | 1 |
fb-rmd-0001 | rmd-mechanics | 2026.9 | Compute this owner's required minimum distribution for the distribution calendar year, in dollars. Respond with the numeric amount only. | {
"account_type": "traditional IRA (owner's lifetime distribution)",
"prior_year_end_balance": 500000,
"age_at_year_end": 73,
"beneficiary_context": "surviving spouse is not the sole designated beneficiary",
"note": "The owner attains age 73 by December 31 of the distribution calendar year. The balance is the... | null | {
"type": "computed",
"value": 18867.92,
"unit": "USD",
"compute": "rmd.uniform-lifetime",
"tolerance": 1
} | {
"full": "The RMD equals the prior December 31 balance divided by the Uniform Lifetime Table denominator for age 73, within $1.",
"severity": "high"
} | [
{
"corpus_id": "cfr-1-401a9-5",
"section": "(a)(1)",
"quote": "is equal to the quotient obtained by dividing the account balance (determined under paragraph (b) of this section) by the applicable denominator (determined under paragraph (c) or (d) of this section, whichever applies)"
},
{
"corpus... | 1 |
fb-rmd-0002 | rmd-mechanics | 2026.9 | Compute the required minimum distribution for this distribution calendar year, in dollars. Respond with the numeric amount only. | {
"account_type": "401(k) individual account (owner's lifetime distribution; owner is retired and past the required beginning date)",
"prior_year_end_balance": 1240000,
"age_at_year_end": 75,
"beneficiary_context": "surviving spouse is not the sole designated beneficiary",
"note": "The owner attains age 75 by... | null | {
"type": "computed",
"value": 50406.5,
"unit": "USD",
"compute": "rmd.uniform-lifetime",
"tolerance": 1
} | {
"full": "The RMD equals the prior-year-end balance divided by the Uniform Lifetime Table denominator for age 75, within $1.",
"severity": "high"
} | [
{
"corpus_id": "cfr-1-401a9-5",
"section": "(b)(1)",
"quote": "the benefit used in determining the required minimum distribution for a distribution calendar year is the account balance as of the last valuation date in the calendar year preceding that distribution calendar year"
},
{
"corpus_id":... | 1 |
fb-rmd-0004 | rmd-mechanics | 2026.9 | What is the applicable denominator (the Uniform Lifetime Table divisor) for this owner's required minimum distribution for the distribution calendar year? Respond with the numeric value only. | {
"account_type": "traditional IRA (owner's lifetime distribution)",
"age_at_year_end": 74,
"beneficiary_context": "surviving spouse is not the sole designated beneficiary",
"note": "The owner attains age 74 by December 31 of the distribution calendar year."
} | null | {
"type": "computed",
"value": 25.5,
"unit": "years",
"compute": "rmd.uniform-lifetime-denominator",
"tolerance": 0
} | {
"full": "The exact Uniform Lifetime Table entry for age 74.",
"severity": "medium"
} | [
{
"corpus_id": "cfr-1-401a9-9",
"section": "(c)",
"quote": "the Uniform Lifetime Table, sets forth the applicable denominator that applies for lifetime distributions to an employee in situations in which the employee's surviving spouse is not the sole designated beneficiary"
}
] | 1 |
fb-rmd-0006 | rmd-mechanics | 2026.9 | Compute the beneficiary's required minimum distribution for this first distribution calendar year, in dollars. Respond with the numeric amount only. | {
"account_type": "inherited traditional IRA (non-spouse eligible designated beneficiary taking annual life-expectancy distributions)",
"prior_year_end_balance": 400000,
"beneficiary_age_first_distribution_year": 55,
"years_since_first_distribution_year": 0,
"note": "This is the beneficiary's first distributi... | null | {
"type": "computed",
"value": 12658.23,
"unit": "USD",
"compute": "rmd.single-life-inherited",
"tolerance": 1
} | {
"full": "The RMD equals the prior year-end balance divided by the Single Life Table entry for age 55, within $1.",
"severity": "high"
} | [
{
"corpus_id": "cfr-1-401a9-5",
"section": "(d)(3)(iii)",
"quote": "determined initially using the beneficiary's age as of the beneficiary's birthday in the calendar year following the calendar year of the employee's death"
},
{
"corpus_id": "cfr-1-401a9-9",
"section": "(b) Single Life Table... | 1 |
fb-rmd-0007 | rmd-mechanics | 2026.9 | Compute the beneficiary's required minimum distribution for the current distribution calendar year, in dollars. Respond with the numeric amount only. | {
"account_type": "inherited traditional IRA (non-spouse eligible designated beneficiary taking annual life-expectancy distributions)",
"prior_year_end_balance": 250000,
"beneficiary_age_first_distribution_year": 62,
"years_since_first_distribution_year": 3,
"note": "The beneficiary attained age 62 in the fir... | null | {
"type": "computed",
"value": 11160.71,
"unit": "USD",
"compute": "rmd.single-life-inherited",
"tolerance": 1
} | {
"full": "The RMD equals the prior year-end balance divided by (initial Single Life factor for age 62 minus 3), within $1. Re-entering the table at the current age is the tested failure mode.",
"severity": "high"
} | [
{
"corpus_id": "cfr-1-401a9-5",
"section": "(d)(3)(iii)",
"quote": "for subsequent calendar years, the designated beneficiary's remaining life expectancy is determined by reducing that initial life expectancy by one for each calendar year that has elapsed after that first calendar year"
},
{
"co... | 1 |
fb-rmd-0009 | rmd-mechanics | 2026.9 | What is the applicable denominator (the Uniform Lifetime Table divisor) for this owner's required minimum distribution for the distribution calendar year? Respond with the numeric value only. | {
"account_type": "traditional IRA (owner's lifetime distribution)",
"age_at_year_end": 90,
"beneficiary_context": "surviving spouse is not the sole designated beneficiary",
"note": "The owner attains age 90 by December 31 of the distribution calendar year."
} | null | {
"type": "computed",
"value": 12.2,
"unit": "years",
"compute": "rmd.uniform-lifetime-denominator",
"tolerance": 0
} | {
"full": "The exact Uniform Lifetime Table entry for age 90.",
"severity": "medium"
} | [
{
"corpus_id": "cfr-1-401a9-9",
"section": "(c)",
"quote": "the Uniform Lifetime Table, sets forth the applicable denominator that applies for lifetime distributions to an employee in situations in which the employee's surviving spouse is not the sole designated beneficiary"
}
] | 1 |
fb-rmd-0011 | rmd-mechanics | 2026.9 | Under the current regulations, what is this owner's applicable age for required minimum distributions? Answer with exactly one option id. | {
"person": "IRA owner born March 14, 1957",
"question_context": "The owner asks at what age required minimum distributions must begin under section 401(a)(9)."
} | [
{
"id": "age-70-half",
"label": "Age 70½"
},
{
"id": "age-72",
"label": "Age 72"
},
{
"id": "age-73",
"label": "Age 73"
},
{
"id": "age-75",
"label": "Age 75"
}
] | {
"type": "derived",
"value": "age-73",
"derivation": "The owner was born March 14, 1957, which is on or after January 1, 1951 and before January 1, 1959. Under 26 CFR 1.401(a)(9)-2(b)(2)(iv), the applicable age for an employee born in that range is age 73. The same applicable-age definition governs IRAs through ... | {
"full": "Selects age-73 based on the 1951–1958 birth-year band.",
"severity": "medium"
} | [
{
"corpus_id": "cfr-1-401a9-2",
"section": "(b)(2)(iv)",
"quote": "In the case of an employee born on or after January 1, 1951, but before January 1, 1959, the applicable age is age 73"
}
] | 1 |
fb-rmd-0012 | rmd-mechanics | 2026.9 | Under the current regulations, what is this participant's applicable age for required minimum distributions? Answer with exactly one option id. | {
"person": "401(k) participant born August 2, 1962",
"question_context": "The participant asks at what age required minimum distributions must begin under section 401(a)(9)."
} | [
{
"id": "age-70-half",
"label": "Age 70½"
},
{
"id": "age-72",
"label": "Age 72"
},
{
"id": "age-73",
"label": "Age 73"
},
{
"id": "age-75",
"label": "Age 75"
}
] | {
"type": "derived",
"value": "age-75",
"derivation": "The participant was born August 2, 1962, which is on or after January 1, 1960. Under 26 CFR 1.401(a)(9)-2(b)(2)(vi), the applicable age for an employee born on or after January 1, 1960 is age 75. Age 73 applies only to the 1951–1958 birth band under paragraph... | {
"full": "Selects age-75 based on the born-after-1959 rule.",
"severity": "medium"
} | [
{
"corpus_id": "cfr-1-401a9-2",
"section": "(b)(2)(vi)",
"quote": "In the case of an employee born on or after January 1, 1960, the applicable age is age 75"
}
] | 1 |
fb-rmd-0013 | rmd-mechanics | 2026.9 | What is this employee's required beginning date — the deadline for her first required minimum distribution? Answer with exactly one option id. | {
"person": "Employee born May 10, 1953, who owns 8% of the employer sponsoring her 401(k) plan (a 5-percent owner for section 401(a)(9) purposes)",
"facts": "She attains age 73 in 2026 and continues working. Her applicable age is 73 (born 1951–1958).",
"question_context": "By what date must her first required mi... | [
{
"id": "dec-31-2026",
"label": "December 31, 2026"
},
{
"id": "april-1-2027",
"label": "April 1, 2027"
},
{
"id": "april-15-2027",
"label": "April 15, 2027"
},
{
"id": "dec-31-2027",
"label": "December 31, 2027"
}
] | {
"type": "derived",
"value": "april-1-2027",
"derivation": "As a 5-percent owner, her required beginning date is April 1 of the calendar year following the calendar year in which she attains the applicable age (26 CFR 1.401(a)(9)-2(b)(3)(i)); the still-working exception in (b)(1)(ii) is unavailable to a 5-percen... | {
"full": "Selects April 1, 2027 — the April 1 following the year she attains age 73, with no still-working deferral for a 5-percent owner.",
"severity": "high"
} | [
{
"corpus_id": "cfr-1-401a9-2",
"section": "(b)(3)(i)",
"quote": "In the case of an employee who is a 5-percent owner, the employee's required beginning date is April 1 of the calendar year following the calendar year in which the employee attains the applicable age"
}
] | 1 |
fb-rmd-0014 | rmd-mechanics | 2026.9 | May this owner satisfy the combined required minimum distributions of all three traditional IRAs by distributing the total from just one of them? Answer with exactly one option id. | {
"person": "IRA owner, age 78, holding three traditional IRAs at three different custodians",
"facts": "The required minimum distribution has been calculated separately for each IRA: $9,200, $4,100, and $2,700. The owner would prefer to take the entire combined amount from the first IRA only.",
"question_context... | [
{
"id": "yes-aggregate",
"label": "Yes — the separately calculated RMDs may be summed and taken from any one or more of the IRAs"
},
{
"id": "no-per-account",
"label": "No — each IRA's RMD must be distributed from that IRA"
},
{
"id": "only-same-custodian",
"label": "Only if the IRAs... | {
"type": "derived",
"value": "yes-aggregate",
"derivation": "26 CFR 1.408-8(e) requires the RMD to be calculated separately for each IRA but permits the sum of those separately calculated amounts to be distributed from any one or more of the individual's IRAs. Nothing in the quoted rule conditions this on the cu... | {
"full": "Selects yes-aggregate, citing the IRA aggregation rule.",
"severity": "medium"
} | [
{
"corpus_id": "cfr-1-408-8",
"section": "(e)(1)(i)",
"quote": "the required minimum distribution must be calculated separately for each IRA and the sum of those separately calculated required minimum distributions may be distributed from any one or more of the IRAs"
}
] | 1 |
fb-rmd-0017 | rmd-mechanics | 2026.9 | Compute this owner's required minimum distribution for the distribution calendar year, in dollars. Respond with the numeric amount only. | {
"account_type": "traditional IRA (owner's lifetime distribution)",
"prior_year_end_balance": 623000,
"age_at_year_end": 78,
"beneficiary_context": "surviving spouse is not the sole designated beneficiary",
"note": "The owner attains age 78 by December 31 of the distribution calendar year. The balance is the... | null | {
"type": "computed",
"value": 28318.18,
"unit": "USD",
"compute": "rmd.uniform-lifetime",
"tolerance": 1
} | {
"full": "The RMD equals the prior December 31 balance divided by the Uniform Lifetime Table denominator for age 78, within $1.",
"severity": "high"
} | [
{
"corpus_id": "cfr-1-401a9-5",
"section": "(a)(1)",
"quote": "is equal to the quotient obtained by dividing the account balance (determined under paragraph (b) of this section) by the applicable denominator (determined under paragraph (c) or (d) of this section, whichever applies)"
},
{
"corpus... | 1 |
fb-rmd-0020 | rmd-mechanics | 2026.9 | What is the applicable denominator (the Uniform Lifetime Table divisor) for this owner's required minimum distribution for the distribution calendar year? Respond with the numeric value only. | {
"account_type": "traditional IRA (owner's lifetime distribution)",
"age_at_year_end": 96,
"beneficiary_context": "surviving spouse is not the sole designated beneficiary",
"note": "The owner attains age 96 by December 31 of the distribution calendar year."
} | null | {
"type": "computed",
"value": 8.4,
"unit": "years",
"compute": "rmd.uniform-lifetime-denominator",
"tolerance": 0
} | {
"full": "The exact Uniform Lifetime Table entry for age 96.",
"severity": "medium"
} | [
{
"corpus_id": "cfr-1-401a9-9",
"section": "(c) Uniform Lifetime Table",
"quote": "the Uniform Lifetime Table, sets forth the applicable denominator that applies for lifetime distributions to an employee in situations in which the employee's surviving spouse is not the sole designated beneficiary"
}
] | 1 |
fb-rmd-0022 | rmd-mechanics | 2026.9 | Compute the required minimum distribution that IRA P's beneficiary (the daughter) must take from IRA P for the calendar year of the owner's death, in dollars. Respond with the numeric amount only. | {
"context": "Traditional IRA owner died in November of the distribution calendar year, after his required beginning date. He attained age 80 in June of that year. He owned two traditional IRAs with different beneficiaries: IRA P (beneficiary: his daughter) and IRA Q (beneficiary: his nephew).",
"ira_balances": [
... | null | {
"type": "computed",
"value": 8547.85,
"unit": "USD",
"compute": "rmd.year-of-death-shortfall-share",
"tolerance": 1
} | {
"full": "Total year-of-death RMD is the combined prior Dec-31 balances divided by the Uniform Lifetime Table denominator for age 80; the $5,000 already distributed reduces it to the shortfall; IRA P's beneficiary owes the shortfall times IRA P's share of the combined balances, within $1.",
"severity": "high"
} | [
{
"corpus_id": "cfr-1-408-8",
"section": "(e)(4)(i)",
"quote": "each of the owner's IRAs is subject to a requirement to distribute a proportionate share of the shortfall for the calendar year to a beneficiary of that IRA, with the proportions based on the account balances determined under paragraph (b)(... | 1 |
fb-rmd-0023 | rmd-mechanics | 2026.9 | Compute this IRA's required minimum distribution for the distribution calendar year, in dollars. Respond with the numeric amount only. | {
"context": "Traditional IRA owner, age 74 at the end of the distribution calendar year; surviving spouse is not the sole designated beneficiary. On December 20 of the preceding year, $40,000 was distributed from a different traditional IRA of hers; she rolled the full amount into this IRA on January 10 of the distr... | null | {
"type": "computed",
"value": 17647.06,
"unit": "USD",
"compute": "rmd.uniform-lifetime-outstanding-rollover",
"tolerance": 1
} | {
"full": "The December 31 balance must be adjusted upward by the $40,000 rollover received in the distribution year before dividing by the Uniform Lifetime Table denominator for age 74, within $1. Using the unadjusted $410,000 is the planted trap.",
"severity": "high"
} | [
{
"corpus_id": "cfr-1-408-8",
"section": "(d)(1)(i)",
"quote": "If the amount rolled over is received in the calendar year following the calendar year in which the amount was distributed, then, for purposes of determining the required minimum distribution for that following calendar year, the account ba... | 1 |
fb-rmd-0025 | rmd-mechanics | 2026.9 | Does the $30,000 qualified charitable distribution satisfy this owner's required minimum distribution for the year? Answer with exactly one option id. | {
"person": "Traditional IRA owner, age 76, with a $30,000 required minimum distribution for the calendar year",
"facts": "During the year the owner directs the custodian to pay $30,000 from the IRA directly to a qualified public charity as a qualified charitable distribution under section 408(d)(8). The QCD is exc... | [
{
"id": "yes-counts-toward-rmd",
"label": "Yes — all amounts distributed from the IRA count toward the RMD regardless of income inclusion, and a QCD is expressly taken into account"
},
{
"id": "no-not-includible",
"label": "No — only distributions includible in gross income count toward the RMD"... | {
"type": "derived",
"value": "yes-counts-toward-rmd",
"derivation": "26 CFR 1.408-8(g)(1) states that all amounts distributed from an IRA are taken into account in determining whether section 401(a)(9) is satisfied regardless of income inclusion, and names a qualified charitable distribution under section 408(d)... | {
"full": "Selects yes-counts-toward-rmd, citing 1.408-8(g)(1).",
"severity": "high"
} | [
{
"corpus_id": "cfr-1-408-8",
"section": "(g)(1)",
"quote": "all amounts distributed from an IRA are taken into account in determining whether section 401(a)(9) is satisfied, regardless of whether the amount is includible in income. Thus, for example, a qualified charitable distribution made pursuant to... | 1 |
fb-rmd-0026 | rmd-mechanics | 2026.9 | Did the trustee-to-trustee transfer satisfy this owner's required minimum distribution for the year? Answer with exactly one option id. | {
"person": "Traditional IRA owner, age 79, with a $22,000 required minimum distribution for the calendar year on his only IRA",
"facts": "In July, the owner moves the entire IRA to a new custodian by direct trustee-to-trustee transfer; nothing is paid to the owner. He takes no other amounts from either account dur... | [
{
"id": "no-rmd-still-required",
"label": "No — a trustee-to-trustee transfer is not a distribution, and the transferor IRA's RMD must still be satisfied"
},
{
"id": "yes-transfer-satisfies",
"label": "Yes — the transfer moved more than the RMD amount out of the transferor IRA"
},
{
"id"... | {
"type": "derived",
"value": "no-rmd-still-required",
"derivation": "26 CFR 1.408-8(d)(4) provides that a trustee-to-trustee transfer between IRAs is not treated as a distribution by the transferor IRA for section 401(a)(9) purposes, and that the transferor IRA's minimum distribution requirement must still be sa... | {
"full": "Selects no-rmd-still-required, citing 1.408-8(d)(4).",
"severity": "high"
} | [
{
"corpus_id": "cfr-1-408-8",
"section": "(d)(4)",
"quote": "the transfer is not treated as a distribution by the transferor IRA for purposes of section 401(a)(9). Accordingly, the minimum distribution requirement with respect to the transferor IRA must still be satisfied."
}
] | 1 |
fb-rmd-0029 | rmd-mechanics | 2026.9 | Is a required minimum distribution due from this Roth IRA for the current year while the owner is alive? Answer with exactly one option id. | {
"person": "Roth IRA owner, age 79, whose only retirement account is a Roth IRA valued at $850,000",
"facts": "The owner has taken no distributions this year. An automated planning tool flags a 'missed RMD' for the year and computes a penalty.",
"question_context": "Whether any required minimum distribution is d... | [
{
"id": "no-rmd-while-alive",
"label": "No — no minimum distributions are required from a Roth IRA while the owner is alive"
},
{
"id": "yes-uniform-table",
"label": "Yes — the Uniform Lifetime Table applies at age 79 like any IRA"
},
{
"id": "yes-after-five-years",
"label": "Yes — l... | {
"type": "derived",
"value": "no-rmd-while-alive",
"derivation": "26 CFR 1.408-8(b)(1)(ii) states flatly that no minimum distributions are required from a Roth IRA while the owner is alive. The RMD rules reach a Roth IRA only after the owner's death, and then as though the owner died before the required beginnin... | {
"full": "Selects no-rmd-while-alive, citing 1.408-8(b)(1)(ii).",
"severity": "medium"
} | [
{
"corpus_id": "cfr-1-408-8",
"section": "(b)(1)(ii)",
"quote": "No minimum distributions are required to be made from a Roth IRA while the owner is alive."
}
] | 1 |
fb-rmd-0030 | rmd-mechanics | 2026.9 | Is a required minimum distribution currently due from this employee's 401(k) plan? Answer with exactly one option id. | {
"person": "Employee, age 75, born in 1951, still working full-time for the employer that maintains her 401(k) plan",
"facts": "She owns no interest in the employer (she is not a 5-percent owner), and the plan uses the regulatory required-beginning-date rule rather than a uniform required beginning date. She has t... | [
{
"id": "no-not-yet-retired",
"label": "No — her required beginning date is April 1 after the later of the applicable-age year or the year she retires, and she has not retired"
},
{
"id": "yes-age-controls",
"label": "Yes — she passed the applicable age, so plan RMDs are due regardless of employ... | {
"type": "derived",
"value": "no-not-yet-retired",
"derivation": "Under 1.401(a)(9)-2(b)(1), the required beginning date for a non-5-percent owner is April 1 of the calendar year following the LATER of the applicable-age year and the year of retirement from the employer maintaining the plan. She is still employe... | {
"full": "Selects no-not-yet-retired, applying the later-of rule.",
"severity": "high"
} | [
{
"corpus_id": "cfr-1-401a9-2",
"section": "(b)(1)",
"quote": "the employee's required beginning date (within the meaning of section 401(a)(9)(C)) is April 1 of the calendar year following the later of"
},
{
"corpus_id": "cfr-1-401a9-2",
"section": "(b)(1)(ii)",
"quote": "The calendar ye... | 1 |
fb-rmd-0031 | rmd-mechanics | 2026.9 | Does this employee's continued employment defer her required minimum distributions from the plan? Answer with exactly one option id. | {
"person": "Employee, age 75, born in 1951, still working full-time for the company that maintains her 401(k) plan",
"facts": "She owns 8 percent of the company and owned it throughout the plan year ending in the calendar year she attained the applicable age. The plan is neither a governmental nor a church plan. S... | [
{
"id": "no-five-percent-owner",
"label": "No — a 5-percent owner's required beginning date is April 1 after the applicable-age year, regardless of continued employment"
},
{
"id": "yes-still-working",
"label": "Yes — the still-working rule applies to every employee of the plan sponsor"
},
{... | {
"type": "derived",
"value": "no-five-percent-owner",
"derivation": "1.401(a)(9)-2(b)(3)(i) fixes a 5-percent owner's required beginning date at April 1 of the year following the applicable-age year, with no retirement prong. Owning 8 percent in the plan year ending in her applicable-age year makes her a 5-perce... | {
"full": "Selects no-five-percent-owner, citing (b)(3)(i).",
"severity": "high"
} | [
{
"corpus_id": "cfr-1-401a9-2",
"section": "(b)(3)(i)",
"quote": "In the case of an employee who is a 5-percent owner, the employee's required beginning date is April 1 of the calendar year following the calendar year in which the employee attains the applicable age."
}
] | 1 |
fb-rmd-0033 | rmd-mechanics | 2026.9 | For section 401(a)(9) purposes, did this employee die before or after his distributions are treated as having begun? Answer with exactly one option id. | {
"person": "Retired employee who began voluntary installment distributions from his profit-sharing plan at age 71",
"facts": "His required beginning date, under 1.401(a)(9)-2(b)(1), falls on April 1 of the year after he attains his applicable age of 73. He dies in February of that applicable-age year — after two y... | [
{
"id": "died-before-distributions-began",
"label": "Before — distributions are not treated as having begun until the required beginning date, regardless of earlier payments"
},
{
"id": "died-after-distributions-began",
"label": "After — two years of installments means distributions had begun"
... | {
"type": "derived",
"value": "died-before-distributions-began",
"derivation": "Under 1.401(a)(9)-2(a)(3)(ii), distributions are not treated as having begun in accordance with section 401(a)(9)(A)(ii) until the required beginning date, even if the employee received payments earlier by election or plan terms — and... | {
"full": "Selects died-before-distributions-began; both distractors are the trap the regulation's own example refutes.",
"severity": "high"
} | [
{
"corpus_id": "cfr-1-401a9-2",
"section": "(a)(3)(ii)",
"quote": "distributions to the employee are not treated as having begun in accordance with section 401(a)(9)(A)(ii) until the employee's required beginning date"
},
{
"corpus_id": "cfr-1-401a9-2",
"section": "(a)(3)(ii)",
"quote": ... | 1 |
fb-rmd-0034 | rmd-mechanics | 2026.9 | Compute the total of the required minimum distributions this owner must take during calendar year 2026, in dollars. Respond with the numeric amount only. | {
"context": "Traditional IRA owner born in 1952; 2025 is her first distribution calendar year (she attains age 73 that year). She takes nothing during 2025 and defers her first required minimum distribution to the April 1, 2026 deadline. Her surviving spouse is not the sole designated beneficiary.",
"first_year_pr... | null | {
"type": "computed",
"value": 31368.85,
"unit": "USD",
"compute": "rmd.deferred-first-year-total",
"tolerance": 1
} | {
"full": "The deferred first-year RMD uses the Dec-31-2024 balance and the age-73 denominator; the 2026 RMD uses the Dec-31-2025 balance and the age-74 denominator; both fall due in 2026 and are summed, within $1.",
"severity": "high"
} | [
{
"corpus_id": "cfr-1-401a9-5",
"section": "(a)(3)",
"quote": "The distribution required for the employee's first distribution calendar year (as described in paragraph (a)(2)(ii) of this section) may be made on or before April 1 of the following calendar year. The required minimum distribution for any o... | 1 |
fb-roll-0001 | rollover-advice | 2026.9 | Judged only against the PTE 2020-02 conditions quoted in this item's sources, which conclusion follows about this arrangement? Answer with exactly one option id. | {
"arrangement": "A broker-dealer (a Financial Institution relying on PTE 2020-02) recommends that a Retirement Investor roll her $480,000 401(k) balance into an IRA at the firm.",
"stipulated_facts": [
"The written fiduciary acknowledgment and the written description of services and material Conflicts of Inter... | [
{
"id": "satisfies-conditions",
"label": "The stipulated facts satisfy the quoted conditions"
},
{
"id": "fails-rollover-documentation",
"label": "It fails the rollover-documentation condition (Section II(c)(3))"
},
{
"id": "fails-fiduciary-acknowledgment",
"label": "It fails the wri... | {
"type": "derived",
"value": "fails-rollover-documentation",
"derivation": "Section II(c)(3) requires the Financial Institution to document the specific reasons that any recommendation to roll over assets from a Plan to another Plan or an IRA is in the Best Interest of the Retirement Investor. The stipulated fac... | {
"full": "Selects fails-rollover-documentation, anchored to II(c)(3).",
"severity": "high"
} | [
{
"corpus_id": "dol-pte-2020-02",
"section": "Section II(c)(3)",
"quote": "documents the specific reasons that any recommendation to roll over assets from a Plan to another Plan or an IRA"
}
] | 1 |
fb-roll-0002 | rollover-advice | 2026.9 | Judged only against the PTE 2020-02 conditions quoted in this item's sources, which conclusion follows about this arrangement? Answer with exactly one option id. | {
"arrangement": "A Financial Institution relying on PTE 2020-02 recommends a plan-to-IRA rollover. The Investment Professional prepares thorough written documentation of the specific reasons the rollover is in the investor's Best Interest.",
"stipulated_facts": [
"The documentation was completed and filed inte... | [
{
"id": "satisfies-conditions",
"label": "The stipulated facts satisfy the quoted conditions"
},
{
"id": "fails-pre-rollover-disclosure",
"label": "It fails the pre-rollover disclosure condition — the documented reasons must reach the investor before the rollover (Section II(b)(3))"
},
{
... | {
"type": "derived",
"value": "fails-pre-rollover-disclosure",
"derivation": "Section II(b)(3) requires that, prior to engaging in a recommended rollover, the Financial Institution provide the documentation of specific reasons to the Retirement Investor. Here the documentation existed (so II(c)(3) is not the fail... | {
"full": "Selects fails-pre-rollover-disclosure; distinguishes the delivery-timing condition from the documentation condition.",
"severity": "high"
} | [
{
"corpus_id": "dol-pte-2020-02",
"section": "Section II(b)(3)",
"quote": "Prior to engaging in a rollover recommended pursuant to the exemption, the Financial Institution provides the documentation of specific reasons for the rollover recommendation"
}
] | 1 |
fb-roll-0003 | rollover-advice | 2026.9 | Judged only against the PTE 2020-02 conditions quoted in this item's sources, which conclusion follows about this arrangement? Answer with exactly one option id. | {
"arrangement": "An investment adviser firm relying on PTE 2020-02 recommends a rollover and provides, before the transaction, a written description of its services and material Conflicts of Interest plus the written documentation of specific reasons for the rollover.",
"stipulated_facts": [
"No written acknow... | [
{
"id": "satisfies-conditions",
"label": "The stipulated facts satisfy the quoted conditions"
},
{
"id": "fails-fiduciary-acknowledgment",
"label": "It fails the written fiduciary-acknowledgment condition (Section II(b)(1))"
},
{
"id": "fails-pre-rollover-disclosure",
"label": "It fa... | {
"type": "derived",
"value": "fails-fiduciary-acknowledgment",
"derivation": "Section II(b)(1) requires a written acknowledgment of fiduciary status. The stipulated facts state fiduciary status was mentioned only orally; an oral statement does not satisfy a condition the quoted text defines as a written acknowle... | {
"full": "Selects fails-fiduciary-acknowledgment; oral disclosure does not meet a written-acknowledgment condition.",
"severity": "high"
} | [
{
"corpus_id": "dol-pte-2020-02",
"section": "Section II(b)(1)",
"quote": "A written acknowledgment that the Financial Institution and its Investment Professionals are fiduciaries under Title I and the Code"
}
] | 1 |
fb-roll-0004 | rollover-advice | 2026.9 | Judged only against the PTE 2020-02 conditions quoted in this item's sources, which conclusion follows about this arrangement? Answer with exactly one option id. | {
"arrangement": "A Financial Institution relying on PTE 2020-02 recommends rolling a $310,000 401(k) into an IRA at the firm.",
"stipulated_facts": [
"Before the transaction, the investor received: a written fiduciary acknowledgment; a written, accurate description of services and material Conflicts of Interes... | [
{
"id": "satisfies-conditions",
"label": "The stipulated facts satisfy the quoted conditions"
},
{
"id": "fails-rollover-documentation",
"label": "It fails the rollover-documentation condition (Section II(c)(3))"
},
{
"id": "fails-retrospective-review-timing",
"label": "It fails the ... | {
"type": "derived",
"value": "satisfies-conditions",
"derivation": "Each quoted condition is satisfied on the stipulated facts: the rollover reasons were documented and delivered before the transaction; the written acknowledgment and conflicts description were provided; every element of the Impartial Conduct Sta... | {
"full": "Selects satisfies-conditions; four months is inside the six-month deadline.",
"severity": "medium"
} | [
{
"corpus_id": "dol-pte-2020-02",
"section": "Section II(d)(4)",
"quote": "The review, report and certification are completed no later than six months following the end of the period covered by the review"
},
{
"corpus_id": "dol-pte-2020-02",
"section": "Section II(c)(3)",
"quote": "docu... | 1 |
fb-roll-0005 | rollover-advice | 2026.9 | May this platform rely on PTE 2020-02 for these transactions? Answer with exactly one option id. | {
"arrangement": "A fintech platform generates rollover recommendations solely through an interactive website: software models produce the advice from information each investor supplies online.",
"stipulated_facts": [
"No Investment Professional ever interacts with the investor or reviews the individual recomme... | [
{
"id": "yes-conditions-met",
"label": "Yes — the Section II conditions are all satisfied"
},
{
"id": "excluded-robo-advice",
"label": "No — Section I(c)(2) excludes advice generated solely by an interactive website without personal interaction with an Investment Professional"
},
{
"id":... | {
"type": "derived",
"value": "excluded-robo-advice",
"derivation": "Section I(c) lists exclusions: the exemption does not apply where the transaction results from investment advice generated solely by an interactive website using software-based models, without personal interaction with an Investment Professional... | {
"full": "Selects excluded-robo-advice; recognizes a structural exclusion defeats condition-level compliance.",
"severity": "high"
} | [
{
"corpus_id": "dol-pte-2020-02",
"section": "Section I(c)(2)",
"quote": "The transaction is a result of investment advice generated solely by an interactive website in which computer software-based models or applications provide investment advice"
}
] | 1 |
fb-roll-0006 | rollover-advice | 2026.9 | Judged only against the PTE 2020-02 conditions quoted in this item's sources, which conclusion follows about this arrangement? Answer with exactly one option id. | {
"arrangement": "An Investment Professional recommends that a 61-year-old participant roll her low-cost 401(k) into a proprietary IRA program paying the firm substantially higher fees.",
"stipulated_facts": [
"The recommendation was made without regard to the investor's stated objectives, risk tolerance, finan... | [
{
"id": "satisfies-conditions",
"label": "The stipulated facts satisfy the quoted conditions"
},
{
"id": "fails-best-interest",
"label": "It fails the Best Interest standard of the Impartial Conduct Standards (Section II(a)(1))"
},
{
"id": "fails-misleading-statements",
"label": "It ... | {
"type": "derived",
"value": "fails-best-interest",
"derivation": "The quoted Best Interest standard requires advice based on the investor's objectives, risk tolerance, financial circumstances, and needs, that does not place the firm's interests ahead of hers. The stipulated facts state the recommendation ignore... | {
"full": "Selects fails-best-interest; timely paperwork does not cure a Best Interest failure.",
"severity": "high"
} | [
{
"corpus_id": "dol-pte-2020-02",
"section": "Section II(a)(1)",
"quote": "based on the investment objectives, risk tolerance, financial circumstances, and needs of the Retirement Investor, and does not place the financial or other interests of the Investment Professional, Financial Institution or any A... | 1 |
fb-roll-0008 | rollover-advice | 2026.9 | Judged only against the PTE 2020-02 conditions quoted in this item's sources, which conclusion follows about this arrangement? Answer with exactly one option id. | {
"arrangement": "A Financial Institution's annual retrospective review of its PTE 2020-02 compliance covers calendar year 2025 (period ending December 31, 2025).",
"stipulated_facts": [
"The review was conducted, reduced to a written report, provided to a Senior Executive Officer, and certified — all completed... | [
{
"id": "satisfies-conditions",
"label": "The stipulated facts satisfy the quoted conditions"
},
{
"id": "fails-retrospective-review-timing",
"label": "It fails the retrospective-review timing condition — completion came more than six months after the period ended (Section II(d)(4))"
},
{
... | {
"type": "derived",
"value": "fails-retrospective-review-timing",
"derivation": "Section II(d)(4) requires the review, report, and certification to be completed no later than six months after the end of the covered period. The period ended December 31, 2025; six months after is June 30, 2026. Completion on Septe... | {
"full": "Selects fails-retrospective-review-timing; computes the six-month deadline from the period end.",
"severity": "medium"
} | [
{
"corpus_id": "dol-pte-2020-02",
"section": "Section II(d)(4)",
"quote": "The review, report and certification are completed no later than six months following the end of the period covered by the review"
}
] | 1 |
fb-wash-0001 | wash-sale-mechanics | 2026.9 | How many dollars of the realized loss are disallowed under the wash-sale rule of section 1091? Respond with the numeric amount only. | {
"shares_sold": 100,
"sale_proceeds_per_share": 32,
"basis_per_share": 47,
"replacement_shares_in_window": 100,
"facts": "A taxable brokerage account sells 100 shares of XYZ common stock at a loss and buys 100 shares of the same XYZ common stock 12 days later. The taxpayer is not a dealer in stock or securit... | null | {
"type": "computed",
"value": 1500,
"unit": "USD",
"compute": "washsale.disallowed-loss",
"tolerance": 0.01
} | {
"full": "All 100 shares' loss is disallowed: 100 replacement shares match all 100 sold shares within the 61-day window.",
"severity": "high"
} | [
{
"corpus_id": "usc-1091",
"section": "1091(a)",
"quote": "within a period beginning 30 days before the date of such sale or disposition and ending 30 days after such date, the taxpayer has acquired (by purchase or by an exchange on which the entire amount of gain or loss was recognized by law), or has ... | 1 |
fb-wash-0002 | wash-sale-mechanics | 2026.9 | How many dollars of the realized loss are disallowed under section 1091? Respond with the numeric amount only. | {
"shares_sold": 250,
"sale_proceeds_per_share": 18.4,
"basis_per_share": 25.15,
"replacement_shares_in_window": 100,
"facts": "The account sells 250 shares of ABC at a loss and repurchases 100 shares of ABC eight days later. No other acquisitions of ABC occur within the 61-day window. The taxpayer is not a d... | null | {
"type": "computed",
"value": 675,
"unit": "USD",
"compute": "washsale.disallowed-loss",
"tolerance": 0.01
} | {
"full": "Only 100 of 250 sold shares are matched by replacement shares; the disallowed loss is the matched shares' loss.",
"severity": "high"
} | [
{
"corpus_id": "usc-1091",
"section": "1091(b)",
"quote": "If the amount of stock or securities acquired (or covered by the contract or option to acquire) is less than the amount of stock or securities sold or otherwise disposed of, then the particular shares of stock or securities the loss from the sal... | 1 |
fb-wash-0004 | wash-sale-mechanics | 2026.9 | What is the per-share basis of the 60 replacement shares after the wash-sale basis adjustment of section 1091(d)? Respond with the numeric amount only. | {
"shares_sold": 100,
"sale_proceeds_per_share": 40,
"basis_per_share": 55,
"replacement_shares_in_window": 60,
"replacement_cost_per_share": 42,
"facts": "The account sells 100 shares of GHI at a loss and buys 60 replacement shares of GHI at $42 per share ten days later. No other GHI acquisitions occur wit... | null | {
"type": "computed",
"value": 57,
"unit": "USD per share",
"compute": "washsale.replacement-basis-per-share",
"tolerance": 0.01
} | {
"full": "Replacement basis per share = basis of the matched sold shares adjusted by the price difference (equivalently, replacement cost plus the disallowed loss per matched share).",
"severity": "high"
} | [
{
"corpus_id": "usc-1091",
"section": "1091(d)",
"quote": "then the basis shall be the basis of the stock or securities so sold or disposed of, increased or decreased, as the case may be, by the difference, if any, between the price at which the property was acquired and the price at which such substant... | 1 |
fb-wash-0007 | wash-sale-mechanics | 2026.9 | How does section 1091 treat the realized loss on the March 10 sale? Answer with exactly one option id. | {
"facts": "On March 10, 2026, a taxable account sells 200 shares of PQR common stock at a loss. On April 8, 2026 — 29 days after the sale — it buys 200 shares of the same PQR common stock. There are no other PQR transactions in 2026. The taxpayer is not a dealer.",
"sale_date": "2026-03-10",
"repurchase_date": "... | [
{
"id": "loss-disallowed-fully",
"label": "The loss is disallowed in full"
},
{
"id": "loss-disallowed-partially",
"label": "The loss is disallowed in part"
},
{
"id": "loss-fully-deductible",
"label": "The loss is fully deductible"
},
{
"id": "no-loss-nothing-to-disallow",
... | {
"type": "derived",
"value": "loss-disallowed-fully",
"derivation": "The statutory window runs 30 days before through 30 days after the March 10 sale, so it closes at the end of April 9, 2026. The April 8 repurchase falls 29 days after the sale, inside the window, and the 200 replacement shares match all 200 sol... | {
"full": "Selects loss-disallowed-fully; the repurchase is inside the 61-day window and fully matched.",
"severity": "high"
} | [
{
"corpus_id": "usc-1091",
"section": "1091(a)",
"quote": "within a period beginning 30 days before the date of such sale or disposition and ending 30 days after such date, the taxpayer has acquired (by purchase or by an exchange on which the entire amount of gain or loss was recognized by law), or has ... | 1 |
fb-wash-0008 | wash-sale-mechanics | 2026.9 | How does section 1091 treat the realized loss on the March 10 sale? Answer with exactly one option id. | {
"facts": "On March 10, 2026, a taxable account sells 200 shares of PQR common stock at a loss. On April 10, 2026 — 31 days after the sale — it buys 200 shares of the same PQR common stock. There are no other PQR transactions within 30 days before or after the sale. The taxpayer is not a dealer.",
"sale_date": "20... | [
{
"id": "loss-disallowed-fully",
"label": "The loss is disallowed in full"
},
{
"id": "loss-disallowed-partially",
"label": "The loss is disallowed in part"
},
{
"id": "loss-fully-deductible",
"label": "The loss is fully deductible"
},
{
"id": "no-loss-nothing-to-disallow",
... | {
"type": "derived",
"value": "loss-fully-deductible",
"derivation": "The disallowance window ends 30 days after the March 10 sale — the end of April 9, 2026. The repurchase on April 10 is 31 days after the sale, outside the window, and no other acquisition of substantially identical stock occurred inside it. Sec... | {
"full": "Selects loss-fully-deductible; day 31 is outside the statutory window.",
"severity": "high"
} | [
{
"corpus_id": "usc-1091",
"section": "1091(a)",
"quote": "within a period beginning 30 days before the date of such sale or disposition and ending 30 days after such date, the taxpayer has acquired (by purchase or by an exchange on which the entire amount of gain or loss was recognized by law), or has ... | 1 |
fb-wash-0009 | wash-sale-mechanics | 2026.9 | How does section 1091 treat the realized loss on the March 10 sale? Answer with exactly one option id. | {
"facts": "A taxable account holds 100 shares of STU. On February 18, 2026 it buys 100 additional shares of STU. On March 10, 2026 — 20 days later — it sells the original 100 shares at a loss and keeps the shares bought in February. There are no other STU transactions within the window. The taxpayer is not a dealer.... | [
{
"id": "loss-disallowed-fully",
"label": "The loss is disallowed in full"
},
{
"id": "loss-disallowed-partially",
"label": "The loss is disallowed in part"
},
{
"id": "loss-fully-deductible",
"label": "The loss is fully deductible — the purchase happened before the sale"
},
{
... | {
"type": "derived",
"value": "loss-disallowed-fully",
"derivation": "The statutory window begins 30 days BEFORE the sale. The February 18 purchase is 20 days before the March 10 sale, inside the window, and its 100 shares match all 100 sold shares. Acquisitions before the sale trigger the disallowance exactly as... | {
"full": "Selects loss-disallowed-fully; the pre-sale purchase inside the 30-days-before leg triggers the rule.",
"severity": "high"
} | [
{
"corpus_id": "usc-1091",
"section": "1091(a)",
"quote": "within a period beginning 30 days before the date of such sale or disposition and ending 30 days after such date, the taxpayer has acquired (by purchase or by an exchange on which the entire amount of gain or loss was recognized by law), or has ... | 1 |
fb-wash-0010 | wash-sale-mechanics | 2026.9 | How does section 1091 treat the result of the March 10 sale? Answer with exactly one option id. | {
"facts": "On March 10, 2026, a taxable account sells 150 shares of VWX for $52 per share; the basis is $38 per share, so the sale produces a gain. On March 20, 2026 it buys 150 shares of VWX. The taxpayer is not a dealer.",
"sale_date": "2026-03-10",
"repurchase_date": "2026-03-20",
"sale_proceeds_per_share":... | [
{
"id": "gain-disallowed",
"label": "The gain is disallowed because of the repurchase"
},
{
"id": "gain-deferred",
"label": "The gain is deferred into the replacement shares' basis"
},
{
"id": "no-loss-nothing-to-disallow",
"label": "Section 1091 does not apply — it disallows losses,... | {
"type": "derived",
"value": "no-loss-nothing-to-disallow",
"derivation": "Section 1091(a) operates only in the case of a loss claimed to have been sustained from a sale or other disposition. This sale produced a $14-per-share gain, so the provision's predicate is absent: the gain is recognized normally and the ... | {
"full": "Selects no-loss-nothing-to-disallow; the rule's predicate is a loss.",
"severity": "medium"
} | [
{
"corpus_id": "usc-1091",
"section": "1091(a)",
"quote": "In the case of any loss claimed to have been sustained from any sale or other disposition of shares of stock or securities"
}
] | 1 |
fb-wash-0011 | wash-sale-mechanics | 2026.9 | How does section 1091 treat the realized loss on the June 2 sale? Answer with exactly one option id. | {
"facts": "On June 2, 2026, a taxable account sells 200 shares of YZA at a loss. On June 18, 2026 it buys 80 shares of YZA. There are no other YZA acquisitions within 30 days before or after the sale. The taxpayer is not a dealer.",
"sale_date": "2026-06-02",
"repurchase_date": "2026-06-18",
"shares_sold": 200... | [
{
"id": "loss-disallowed-fully",
"label": "The loss is disallowed in full"
},
{
"id": "loss-disallowed-partially",
"label": "The loss is disallowed in part — only the matched shares"
},
{
"id": "loss-fully-deductible",
"label": "The loss is fully deductible"
},
{
"id": "no-lo... | {
"type": "derived",
"value": "loss-disallowed-partially",
"derivation": "The June 18 repurchase is 16 days after the sale, inside the window, but only 80 replacement shares were acquired against 200 sold. Under section 1091(b) and the matching rule of 26 CFR 1.1091-1(c), only the loss on the 80 matched shares is... | {
"full": "Selects loss-disallowed-partially; 80 of 200 shares are matched.",
"severity": "high"
} | [
{
"corpus_id": "usc-1091",
"section": "1091(b)",
"quote": "If the amount of stock or securities acquired (or covered by the contract or option to acquire) is less than the amount of stock or securities sold or otherwise disposed of, then the particular shares of stock or securities the loss from the sal... | 1 |
fb-wash-0015 | wash-sale-mechanics | 2026.9 | How many dollars of the realized loss are disallowed under section 1091? Respond with the numeric amount only. | {
"shares_sold": 300,
"sale_proceeds_per_share": 9.85,
"basis_per_share": 12.6,
"replacement_shares_in_window": 180,
"facts": "The account sells 300 shares of EFG at a loss and repurchases 180 shares of EFG eleven days later. No other EFG acquisitions occur within the 61-day window. The taxpayer is not a deal... | null | {
"type": "computed",
"value": 495,
"unit": "USD",
"compute": "washsale.disallowed-loss",
"tolerance": 0.01
} | {
"full": "Only the 180 matched shares' loss is disallowed.",
"severity": "high"
} | [
{
"corpus_id": "usc-1091",
"section": "1091(b)",
"quote": "If the amount of stock or securities acquired (or covered by the contract or option to acquire) is less than the amount of stock or securities sold or otherwise disposed of, then the particular shares of stock or securities the loss from the sal... | 1 |
fb-wash-0016 | wash-sale-mechanics | 2026.9 | How does section 1091 treat the realized loss on the July 1 sale? Answer with exactly one option id. | {
"facts": "On July 1, 2026, a taxable account sells 150 shares of HIJ common stock at a loss. On July 31, 2026 — exactly 30 days after the sale — it buys 150 shares of the same HIJ common stock. There are no other HIJ transactions within the window. The taxpayer is not a dealer.",
"sale_date": "2026-07-01",
"rep... | [
{
"id": "loss-disallowed-fully",
"label": "The loss is disallowed in full — day 30 is inside the window"
},
{
"id": "loss-disallowed-partially",
"label": "The loss is disallowed in part"
},
{
"id": "loss-fully-deductible",
"label": "The loss is fully deductible — the window closed be... | {
"type": "derived",
"value": "loss-disallowed-fully",
"derivation": "The statutory period ends 30 days after the sale date. July 31, 2026 is exactly 30 days after July 1, 2026, so the repurchase falls on the final day of the period — inside it, not past it — and the 150 replacement shares match all 150 sold shar... | {
"full": "Selects loss-disallowed-fully; day 30 is the last day inside the window.",
"severity": "high"
} | [
{
"corpus_id": "usc-1091",
"section": "1091(a)",
"quote": "within a period beginning 30 days before the date of such sale or disposition and ending 30 days after such date, the taxpayer has acquired (by purchase or by an exchange on which the entire amount of gain or loss was recognized by law), or has ... | 1 |
fb-wash-0019 | wash-sale-mechanics | 2026.9 | How many dollars of the realized loss are disallowed under section 1091? Respond with the numeric amount only. | {
"facts": "On April 14, 2026, a taxable account sells 200 shares of KLM common stock for $31.00 per share; the basis is $45.00 per share. It buys 90 shares of KLM on April 24, 2026 and another 60 shares on May 8, 2026. There are no other KLM acquisitions within 30 days before or after the sale.",
"shares_sold": 20... | null | {
"type": "computed",
"value": 2100,
"unit": "USD",
"compute": "washsale.disallowed-loss",
"tolerance": 0.01
} | {
"full": "Both in-window purchases count: 150 replacement shares wash 150 of the 200 shares sold at a $14.00-per-share loss, so $2,100 is disallowed and $700 remains deductible.",
"severity": "high"
} | [
{
"corpus_id": "usc-1091",
"section": "1091(a)",
"quote": "within a period beginning 30 days before the date of such sale or disposition and ending 30 days after such date, the taxpayer has acquired (by purchase or by an exchange on which the entire amount of gain or loss was recognized by law), or has ... | 1 |
fb-wash-0021 | wash-sale-mechanics | 2026.9 | What is the per-share basis of the 40 replacement shares after the wash-sale basis adjustment of section 1091(d)? Respond with the numeric amount only. | {
"facts": "On October 6, 2026, a taxable account sells 100 shares of QRS common stock for $33.75 per share; the basis is $40.50 per share. On October 27, 2026 it buys 40 shares of QRS for $35.20 per share. There are no other QRS acquisitions within 30 days before or after the sale.",
"shares_sold": 100,
"sale_pr... | null | {
"type": "computed",
"value": 41.95,
"unit": "USD",
"compute": "washsale.replacement-basis-per-share",
"tolerance": 0.01
} | {
"full": "The 40 replacement shares wash 40 sold shares; each carries its $35.20 cost plus the $6.75-per-share disallowed loss, a basis of $41.95 per share.",
"severity": "high"
} | [
{
"corpus_id": "usc-1091",
"section": "1091(a)",
"quote": "within a period beginning 30 days before the date of such sale or disposition and ending 30 days after such date, the taxpayer has acquired (by purchase or by an exchange on which the entire amount of gain or loss was recognized by law), or has ... | 1 |
fb-wash-0022 | wash-sale-mechanics | 2026.9 | How does section 1091 treat the realized loss on the February 5 sale? Answer with exactly one option id. | {
"facts": "A taxable account holds two 100-share lots of TUV common stock. On January 12, 2026 it sells the first lot at a loss. On January 20, 2026 it buys 100 shares of TUV, and that purchase disallows the January 12 loss under section 1091. On February 5, 2026 it sells the second 100-share lot at a loss. Apart fr... | [
{
"id": "loss-fully-deductible",
"label": "Fully deductible — the January 20 acquisition already washed the January 12 loss and is disregarded for any other loss"
},
{
"id": "loss-disallowed-fully",
"label": "Fully disallowed — the January 20 purchase is within 30 days of the February 5 sale"
... | {
"type": "derived",
"value": "loss-fully-deductible",
"derivation": "Applying losses in disposition order per 1.1091-1(b), the January 20 acquisition washes the January 12 loss first. Under 1.1091-1(e), an acquisition that resulted in the nondeductibility of one loss is disregarded in determining the deductibili... | {
"full": "Selects loss-fully-deductible, citing the disregard rule of 1.1091-1(e).",
"severity": "high"
} | [
{
"corpus_id": "cfr-1-1091-1",
"section": "(e)",
"quote": "The acquisition of any share of stock or any security which results in the nondeductibility of a loss under the provisions of this section shall be disregarded in determining the deductibility of any other loss."
},
{
"corpus_id": "cfr-1... | 1 |
fb-wash-0024 | wash-sale-mechanics | 2026.9 | What is the per-share basis of the 80 replacement shares after the wash-sale basis adjustment of section 1091(d)? Respond with the numeric amount only. | {
"facts": "On November 9, 2026, a taxable account sells 80 shares of RST common stock for $41.00 per share; the basis is $50.00 per share. On November 24, 2026 it buys 80 shares of RST for $39.00 per share. There are no other RST acquisitions within 30 days before or after the sale.",
"shares_sold": 80,
"sale_pr... | null | {
"type": "computed",
"value": 48,
"unit": "USD",
"compute": "washsale.replacement-basis-per-share",
"tolerance": 0.01
} | {
"full": "All 80 shares are washed; each replacement share carries its $39.00 cost plus the $9.00-per-share disallowed loss — $48.00 per share, within a cent.",
"severity": "high"
} | [
{
"corpus_id": "usc-1091",
"section": "1091(a)",
"quote": "within a period beginning 30 days before the date of such sale or disposition and ending 30 days after such date, the taxpayer has acquired (by purchase or by an exchange on which the entire amount of gain or loss was recognized by law), or has ... | 1 |
fb-wash-0026 | wash-sale-mechanics | 2026.9 | How does section 1091 treat the realized loss on the April 7 sale? Answer with exactly one option id. | {
"facts": "On April 7, 2026, a taxable account sells 150 shares of LMN common stock at a loss. On April 20, 2026 — 13 days later — the account acquires 150 shares of LMN, not by purchase, but in a taxable exchange in which the entire amount of the account's gain on the property surrendered was recognized by law. The... | [
{
"id": "loss-disallowed-fully",
"label": "Fully disallowed — acquisition by an exchange on which the entire gain or loss was recognized triggers the rule just as a purchase does"
},
{
"id": "loss-fully-deductible",
"label": "Fully deductible — only acquisitions by purchase trigger the wash-sale... | {
"type": "derived",
"value": "loss-disallowed-fully",
"derivation": "Section 1091(a) reaches a taxpayer who 'has acquired (by purchase or by an exchange on which the entire amount of gain or loss was recognized by law)' substantially identical stock within the 61-day period, and 1.1091-1(f) defines 'acquired' th... | {
"full": "Selects loss-disallowed-fully, citing the exchange branch of the acquisition definition.",
"severity": "medium"
} | [
{
"corpus_id": "usc-1091",
"section": "1091(a)",
"quote": "within a period beginning 30 days before the date of such sale or disposition and ending 30 days after such date, the taxpayer has acquired (by purchase or by an exchange on which the entire amount of gain or loss was recognized by law), or has ... | 1 |
WealthSchema Planning Benchmark · now part of FiduciaryBench
New (2026-09): the fiduciarybench config carries the public split of
FiduciaryBench's conduct suites — Reg BI suitability, RMD mechanics, and
wash-sale mechanics — where every answer key is computed by code or derived
from a quoted primary-source passage (SEC, FINRA, IRS/Treasury, U.S. Code)
that exact-matches a locally held, versioned corpus. Per-item provenance
pages, methodology, and the standing challenge policy:
https://www.wealthschema.com/benchmark · Harness: pip install fiduciarybench.
The planning configs below are FiduciaryBench's planning-calculations family.
Is your AI giving 2026 advice — or 2025 advice? Evaluation tasks for AI financial-advice systems, with answer keys built from primary-source-verified U.S. regulatory figure tables — including the enumerated wrong-but-plausible stale values (forbidden figures) with reason codes, so stale answers are countable, not anecdotal.
- v2 (current): 50 tasks — the open split of the AI Eval Sets TY2026
corpus. Rule-grounding and threshold/cliff families, floor/standard
difficulty. Each task carries
answer_key.required_figures(value + unit + establishing source document, e.g. IRS Notice 2025-67) andanswer_key.forbidden_figures(stale/superseded/derived values with reason codes:prior_year_value,superseded,derived_not_published,fabricated_forward_figure, …). Scoring is fully mechanical — no LLM judge. - v1 (superseded, kept for citation continuity): the original 14-task
benchmark with
expected/computationkeys.
Headline metric: the Stale Figure Rate (SFR)
SFR = attempts asserting ≥1 forbidden figure as current ÷ figure-bearing attempts. In the pre-registered pilot of record (40 held-out tasks, 4 systems from 3 labs, k=3), 29% of figure-bearing attempts (86/300) cited a stale or fabricated regulatory figure; per-system SFR ranged 7%–63%, and errors repeated across attempts (pass^3 ≈ pass@1). Full protocol, substitution log, and per-system results: https://www.wealthschema.com/resources/methodology/planning-benchmark-pilot-of-record · live scoreboard: https://www.wealthschema.com/benchmark.
Using it
Blind evaluation: present prompt.system + prompt.user, k=3 attempts;
score mechanically against answer_key (required figures present, forbidden
figures absent as the operative value, typed expectations matched). The live
API serves the same data with a blind mode:
https://www.wealthschema.com/api/benchmark/v2?withhold_answers=true.
Report pass@1, pass^k, and SFR with the denominator, k, and vintage.
Splits and what's deliberately absent
This open split is 50 of a 471-task corpus. The adversarial categorical-flip family, all decision-recall tasks, and a held-out reserve (including all 40 pilot tasks) are never published — that is what keeps the maintainer-run scoreboard re-runnable and third-party comparisons meaningful. The commercial families are sold as one-time eval packs: https://www.wealthschema.com/ai-eval-sets.
License and training use
Free to use for evaluation, benchmarking, and research with attribution
("WealthSchema Planning Benchmark, wealthschema.com/benchmark").
training_use_permitted: false on every record — do not train,
fine-tune, or include these tasks in training corpora; training on
evaluation data destroys its value for everyone it is compared against.
Figures are informational, cited to primary government documents, and are
not tax, legal, or financial advice.
All scenarios are synthetic; no real persons, households, or accounts.
Vintage: each answer key is correct for its stated tax year (vintage,
as_of_date). Figures roll every January; a new vintage of this dataset
ships each year.
Questions: support@wealthschema.com · https://www.wealthschema.com/for-agents
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