A Roadmap for Preparation and Delivery of New Form CRS

In 2019, the SEC issued guidance on the standard of conduct applicable to investment advisers and adopted Regulation Best Interest, which enhanced the standard of conduct for brokers. It also required broker-dealers and advisers to provide retail investors with a relationship summary on Form CRS (Form CRS). The compliance date for filing and delivery of Form CRS is June 30, 2020. In a recent seminar by ACA Compliance Group, partner Joshua Broaded and senior principal consultant Christopher Michailoff discussed the fast-approaching filing and delivery deadline and offered step-by-step guidance for complying with the requirements and completing Form CRS. This article summarizes the key takeaways from their presentation. For more on Form CRS and additional upcoming filing deadlines, see “Compliance Corner Q1‑2020: Regulatory Filings and Other Considerations That Hedge Fund Managers Should Note in the Coming Quarter” (Jan. 23, 2020).

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