New SEC Risk Alerts

The SEC today issued Risk Alerts identifying areas related to Form CRS and Regulation BI on which examiners will focus during upcoming exams. The SEC indicated in today’s Form CRS Risk Alert that RIAs need to meet content, delivery and record keeping requirements. The SEC referred RIAs to the Form CRS Adopting Release and Small Entity Compliance Guide for more information. The SEC’s Regulation BI Risk Alert reviewed the four component obligations: a Disclosure Obligation, a Care Obligation, a Conflict of Interest Obligation, and a Compliance Obligation.

The press release announcing the risk alerts quoted Pete Driscoll, Director of OCIE, stating that during initial examinations, “our focus will be on firms continuing good faith and reasonable efforts, including taking into account firm-specific effects from disruptions caused by COVID-19.”  The press release also emphasized the importance of these regulations and the urgency to implement.  “Regulation Best Interest and Form CRS are key components of a broader package of rules and interpretations, adopted contemporaneously on June 5, 2019, to enhance the quality and transparency of retail investors’ relationships with broker-dealers and investment advisers. The compliance date for Regulation Best Interest and Form CRS is June 30, 2020.”

Check out the Form CRS Automator for RIAs and BDs, and contact us regarding Regulation BI implementation services. CSS’s Form CRS Automator makes filing Form CRS fast and efficient and gives you confidence that you have it right. Our Regulation BI checklists will help make sure you are on the right track for your examination. For those not yet started, we can help you establish the necessary policies and disclosures. Email our compliance experts at

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