The SEC’s Proposed Form CRS: Does It Accomplish Its Goals? (Part Two of Two)

When the SEC recently released proposed Form CRS, it explained that the new short-form disclosure document is intended to give retail investors simple, easy-to-understand information about the nature of their relationships with their investment professionals; prompt them to ask informed questions; and enable them to compare firms that offer the same or substantially similar services. Does Form CRS actually accomplish these goals, however? This two-part series analyzes the proposed Form CRS requirements, reviews various issues the form raises and provides insight from lawyers and compliance professionals on the proposal. This second article in the series discusses whether the form is likely to achieve the SEC’s stated goals and explores potential issues it raises for registered investment advisers. The first article provided an overview of proposed Form CRS and its key requirements. For additional proposals by the SEC that would further regulate fund managers, see “SEC Emphasizes Investment Adviser Fiduciary Duty and Proposes Enhanced Adviser Regulation” (May 10, 2018).

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