Where the firm or the individual recommends a sequence of transactions, each may look acceptable alone, yet the series must also be judged as a whole against the customer's investment profile. There must be reasonable grounds to conclude that the series as a whole is not excessive and serves the customer's interest, with the firm's interest kept behind the customer's. This replaces the former control-based churning test; no de facto control of the account is required.
The graph holds this control, the 0 it maps to, and the evidence behind each claim, over MCP and REST.