The broker-dealer must have, keep current and actually enforce written procedures that are reasonably built to identify every conflict of interest associated with retail recommendations and, as a minimum response, either disclose each one in line with the disclosure obligation or eliminate it. The obligation is the firm's, not the individual's, and it requires an ongoing conflict inventory rather than a one-off review.
The graph holds this control, the 0 it maps to, and the evidence behind each claim, over MCP and REST.