Technology Advances Here and On the Way for Form CRS

CSS featured a strong presence at the recent 2019 BAM + Loring Ward Advisor National Conference in St. Louis, Mo. The conference, titled “In Our Element,” explored the chemistry of investment advisors’ relationships with their clients and the keys to successfully building those relationships.

Within that context, CSS’s compliance presentation outlining the purpose and implementation of Form CRS was a perfect match. The new Form CRS, a/k/a Form ADV Part 3, must be completed by SEC registered investment advisers and filed with the SEC by June 30, 2020. The new Form CRS is designed to highlight differences between the key characteristics of broker-dealers and investment advisers, i.e. the elements of the relationships between registered investment advisers (RIAs) and registered brokers-dealers (BDs), and their respective clients.

Form CRS is a continuation in the evolution of our U.S. regulatory thinking regarding the need to clarify the different obligations that RIAs and BDs owe to the investors they serve. It’s another new regulatory obligation requiring more time and energy from Chief Compliance Officers and all of the financial professionals at RIAs and BDs. CSS will soon announce more about its regulatory solutions for Form CRS and the related Regulation BI applicable to BDs.

The conference organizers tied it all together so well. Amidst numerous sessions about operating an independent advisory business, the most enjoyable was a sit down with Bill Nye, the Science Guy. He told us to realize and remember that changing people’s minds from engrained beliefs can take years.  For example, he poignantly identified the changing understanding by the retail investor that stockbrokers do not by their very nature have market insight.

The Science Guy provided his own example. He explained that he had stubbornly been opposed to genetically modified foods but with new information, including the possibility of growing vegetables that produce vitamin B-12, he has changed his mind. He also noted that Burger King’s Impossible Whopper is so good because the makers genetically modified plants successfully to make the plants taste like meat.

The Science Guy concluded that we all should be optimistic to create great change. As an example, he told us that our grandchildren will wonder why we drove such inefficient vehicles.

CSS feels the same way about compliance and regulatory reporting solutions. When Form PF was introduced for private fund managers almost a decade ago, CSS was the leader in providing a solution to the market. Today, CSS provides shareholder threshold and position limit monitoring globally, transaction analysis and reporting solutions required by the latest European Union regulations. Same thing for Form CRS and Regulation BI. When you see our solution, you will be optimistic about change.


Need more help on Form CRS? Join our upcoming ComplianceCast webinar, “Form CRS and Conversation Starters Made Easy: Practical Application & Tips for Investment Advisers, Dual Registrants, and Broker-Dealers,” on Nov. 21. To register, click here.


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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.

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