The Skinny on Form CRS
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Who should care?
SEC registered investment advisers, broker-dealers, and dual registrants, who do business with retail investors.
Why Form CRS?
Form CRS (client relationship summary) is designed to provide investors with simple and comparable, easy-to-understand information about the nature of their relationship with their financial professional.[1]
What are the Deadlines?
- By June 30, 2020, all investment advisers, broker-dealers, and dual-registrants must submit their documentation.
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- Broker-dealers will need to file Form CRS through CRD (Central Registration Depository)
- Investment advisers submit Form ADV, Part 3 through IARD (Investment Adviser Registration Depository) (see instructions)
- Dual registrants are required to file both Form ADV, Part 3 and Form CRS
- The forms must be delivered to all retail clients within by July 30, 2020.
Examination Tips?
- The SEC and FINRA are taking their examinations seriously. In addition to completing the form, all firms should pay particular attention to their record retention capabilities and making sure they are tracking communications, disclosures, and versioning.
- The guidelines for filing Form CRS are available on the SEC’s website, along with very resourceful FAQ’s.
- If you need guidance on the filing process or need assistance with the e-delivery and record keeping component of the above forms, we are available for support.
How can I eDeliver Form CRS to clients?
InvestorCOM ComplianceExpress can be used to easily and efficiently e-deliver and track all mandatory compliance and firm specific documentation.
Watch this video to learn more.
[1] https://www.sec.gov/news/press-release/2019-89