SEC Resolves Additional Enforcement Proceedings Over Filing, Delivery and Content of Form CRS

It has been almost two years since investment advisers and broker-dealers with retail clients and customers were required to file and deliver their initial customer relationship summaries on Form CRS. In late 2021, the SEC began resolving enforcement proceedings against registrants that failed to file Form CRS when required to do so. The SEC has continued its crackdown on delinquent registrants, recently announcing settlements with six advisers and six broker-dealers. Unlike earlier enforcement actions, which focused on the filing and delivery deadlines, these latest actions also cited certain registrants for failing to comply strictly with the Form CRS language and content requirements. This article explores the circumstances giving rise to the latest enforcement proceedings and the terms of the settlements. These actions illustrate that the SEC will have little tolerance for untimely filings. See “Six Takeaways From the SEC’s FY 2021 Enforcement Results” (Jan. 27, 2022); and “Speeches Outline the Ethos, Direction and Priorities of the SEC’s Division of Enforcement Under Gurbir Grewal” (Jan. 13, 2022).

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