OCIE Risk Alerts on Reg BI and Form CRS: Key Takeaways for Broker-Dealers and Advisers (Part Two of Two)

Broker-dealers and investment advisers that are subject to Form CRS and Regulation Best Interest (Reg BI) must comply with those new rules by June 30, 2020. To aid in firms’ compliance efforts, the SEC’s Office of Compliance Inspections and Examinations (OCIE) recently issued a pair of risk alerts (Risk Alerts) on post‑June 30 examinations focusing on compliance with Reg BI and Form CRS. According to the SEC, the purpose of the Risk Alerts is to provide registered advisers and broker-dealers with “information about the scope and content of initial examinations after the compliance date.” OCIE’s goal is “to empower firms to assess their level of preparedness as the compliance date nears,” note the Risk Alerts. This second article in a two-part series provides key takeaways from the Risk Alerts for broker-dealers and investment advisers. The first article discussed the key provisions of the Risk Alerts, as well as the status of the June 30 compliance deadline. See “The SEC’s Response to the Coronavirus Pandemic and Its 2020 Exam Priorities” (May 14, 2020).

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