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...