The SEC has been cracking down on broker-dealers and RIA firms that fail to file and deliver their Regulation Best Interest disclosure forms, including Client Relationship Summaries, or Forms CRS, in a timely manner. Last July, the SEC charged a whopping 27 firms for failure to report updates to their Forms CRS — and this enforcement trend doesn’t look like it will let up any time soon.
Although no annual filing of Forms CRS is required, the forms must be updated and refiled within 30 days of any material changes. Unfortunately for CCOs, the SEC doesn’t provide templates. So when changes occur, all firms must build and update their own documents.
CCOs have a difficult road ahead of them and will need to pay close attention to several important updates in order to avoid inquiries and audits. If you have questions about who receives the forms, what to include, or delivery requirements — like due dates, length, and format — AdvisorLaw can help.
Our compliance team includes both attorneys and certified securities compliance professionals (CSCPs). We always offer a complimentary attorney consultation.
Learn more about our RIA Compliance Services or contact us to consult with a team member.