SEC Resolves Enforcement Proceedings Over Late Filing and Delivery of Form CRS

In June 2019, the SEC adopted Form CRS, which requires investment advisers and broker-dealers with retail clients to provide plain-English disclosures to those clients about the critical terms of the firm’s relationship with its clients. Firms subject to that requirement had to file an initial Form CRS with the SEC or FINRA, and begin delivering the form to prospective clients, by June 30, 2020. They also had to deliver the form to existing clients by July 30, 2020. The SEC recently resolved enforcement proceedings against 21 investment advisers and six broker-dealers that allegedly failed to comply with the Form CRS filing and delivery requirements in a timely manner. This article discusses the Form CRS filing requirements, the alleged compliance failures and the terms of the settlement orders. See “A Roadmap for Preparation and Delivery of New Form CRS” (Mar. 19, 2020).

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