The North American Securities Administrators Association’s (NASAA) Regulation Best Interest (Reg BI) Implementation Committee (Committee) conducted two surveys with the stated purpose of measuring the impact of the U.S. Securities and Exchange Commission’s (SEC) Reg BI and level of
compliance with the regulation. While any effort to measure the effect of public policy is laudable, a careful review of the Committee’s research effort uncovered significant deficiencies, including the notable failure to follow eight well-established and critical survey research practices. The flaws in the
design and execution of this research mean that its findings and conclusions cannot be relied upon as accurate measures of firm behavior, compliance with Reg BI, the impact of the regulation, or the extent to which the interests of investors are well-served.