Regulatory Update: SEC Observations Regarding Implementation of Reg BI’s Form CRS Disclosures
The SEC Staff issued observations and findings related to Regulation BI and Form CRS Disclosures, which include the following topics. You may review the full SEC release here: https://www.sec.gov/news/statement/staff-statement-form-crs-disclosures-121721
Use of Technical Language, Including Disclaimers.
Omission of Required Information.
Reliance on Proposed, Rather than Final Instructions.
Lack of Specific References to More Detailed Information.
Shortcomings in Descriptions of Relationships and Services; Fees, Costs, Conflicts, and Standard of Conduct.
Modification and/or Supplementation of the Disciplinary History Disclosure.
Issues with Prominently Displaying Relationship Summary on Firm Website.
Issues with Description of Affiliate Relationships.
Poor Design.
Use of Marketing Language.
Boilerplate.
The following are important FORM CRS resources:
