What proactive measure are registrants and their firms expected to take to identify conflicts of interest?

a$.$ Have the registrant complete training on identifying conflicts of interest to rectify compliance issues.

b$.$ Explain all conflicts of interest to a client as soon as possible, once identified.

c$.$ Consider what potential conflicts of interest may arise during product origination and the due diligence phase.

d$.$ Have the registrant report any conflicts of interest encountered to the firm's governing council each week.