SEC’s New Committee Begins Review of Form CRS Filings

The SEC’s Divisional Standards of Conduct Implementation Committee launched its review of Form CRS from a cross section of RIAs and BDs to assess compliance with the content and format requirements. Initial observations from the Committee have identified examples of relationship summaries that may lack certain disclosures or could be clearer or otherwise improved. The Committee also indicated the summaries reviewed to date generally reflect effort by firms to meet the content and format requirements, and have identified good examples of simple, clear disclosures.

The inter-Divisional Standards of Conduct Implementation Committee was established when Form CRS was adopted and includes representatives from the SEC’s Division of Investment Management, Division of Trading and Markets, Division of Economic and Risk Analysis, and Office of Compliance Inspections and Examinations.
The Committee will share best practices and provide feedback on the filings and is planning to host a roundtable this fall to share additional thoughts following the review of the initial filings.

The Committee stated, “Particular firms may need to consider ways to improve their relationship summaries and determine whether any specific amendments, or broader change in their overall approach, would be appropriate.”

CSS has also been reviewing compliance with the requirements by reviewing a sampling of public filings, utilizing its tools to identify where refinements are needed, and deficiencies exist. We will be publishing our own observations soon.

The SEC encouraged firms to continue to review and refine their relationship summaries, and familiarize themselves with the specific requirements of Form CRS by reviewing the Instructions to Form CRS, the Form CRS Adopting Release, the Frequently Asked Questions on Form CRS, and the Small Entity Compliance Guide.

For more information on CSS’s Form CRS Automator and Reg BI compliance services, please contact us at:

Subscribe to CSS Blog

CSS frequently publishes blog posts which are written by our team from their observations in the field, at conferences and through experiences with compliance professionals. These posts are designed to further knowledge and share industry best practices. Topics run the gamut, including Form ADV, cybersecurity, MiFID II, position limit monitoring, technology challenges and more. Complete and submit the brief form below to receive notifications when we publish new content.

Latest Content

Do You Feel Confident Your Password Hasn’t Been Hacked?

As a cybersecurity consultant, I am often asked if some of the threats we industry practitioners talk about are overstated. Hyped up fear as a sales tactic. The simple answer is no. The fear is not overstated, and the risks all too real – which helps to explain why cyber remains a top priority for … Continued

Proposed Amendment to 13F – What This Really Means?

The SEC released a proposed amendment to Form 13F on July 10 to update the reporting threshold for institutional investment managers and make other targeted changes. The threshold has not been adjusted since the Commission adopted Form 13F over 40 years ago. New Proposed Reporting Threshold: The proposal would raise the reporting threshold to $3.5 … Continued

SEC Issues New Cyber Risk Alert to Financial Firms

Financial firms have a bigger target on their backs at the moment, according to a new risk alert issued July 10, 2020 by the Securities and Exchange Commission’s Office of Compliance Inspections and Examinations (OCIE).  This new risk alert on ransomware cautions investment advisers, broker-dealers, and investment companies that OCIE has recently observed a marked … Continued