Form CRS is a client or customer relationship summary. Advisers and brokers are required to deliver a relationship summary to you beginning in summer 2020. The relationship summary contains important information about the adviser or broker. Show
Choosing or continuing to work with a financial professional is an important decision. Advisers and brokers offer different types of services and are paid differently. Reading a relationship summary can help you decide if an adviser or broker is right for you. A relationship summary tells you about: the types of services the firm offers; the fees, costs, conflicts of interest, and required standard of conduct associated with those services; whether the firm and its financial professionals have reportable legal or disciplinary history; and, how to get more information about the firm. A relationship summary also includes questions to help you begin a discussion with an adviser or broker about the relationship, including their services, fees, costs, conflicts, and disciplinary information. Beginning in the summer of 2020, advisers and brokers will give you a relationship summary when starting a relationship with you or when your account changes (e.g., you rollover an IRA). If the information in the relationship summary changes, your adviser or broker will be required to give you a new relationship summary or communicate the changes through another disclosure that must be delivered to you. You can also always request a relationship summary. If you already have a brokerage or advisory account, you will get your first relationship summary by July 30, 2020. You will be able to find a firm’s relationship summary and find more information about a firm using the free and simple search tool on Investor.gov. Form CRS—short for client or customer relationship summary—is a mandatory written disclosure that broker-dealers and registered investment advisors (RIAs) must provide to clients that discloses key information about the broker-dealer’s background and practices. It is part of the Securities and Exchange Commission’s (SEC) ongoing efforts to protect investors by establishing rules on how broker-dealers can operate. The point of Form CRS, which started being given to investment clients in mid-2020, is to give individual investors information about the broker-dealer firm’s background and any past legal and disciplinary problems, and to detail fees, commissions, and other information that can be used to evaluate and compare potential investment managers. Key Takeaways
How Does Form CRS Work?The SEC’s Regulation Best Interest rule requires that broker-dealers and registered investment advisors provide clients with the Form CRS. The relationship summary includes the following information:
NoteAn investor can review a firm’s Form CRS to get an overview of what services the broker-dealer or advisory firm provides and what other firms it’s involved with, such as custodians who hold investments. The form also discloses the types of fees that are charged, including asset management fees or commissions, and whether potential conflicts of interest exist, such as when an advisor might receive a commission for recommending specific investments. The form also must describe the rules and regulations that apply to the advisors. Form CRS further discloses whether any disciplinary or legal actions have been taken against the firm and its advisors under SEC rules or by other financial regulators, and tells investors where to find disclosures of those events. Finally, the form will suggest questions to guide an investor in evaluating a potential advisor, such as, “How much would I pay per year for an advisory account?” Form CRS must be presented before placing an order for an individual investor or before opening a brokerage account for an investor. And the firm must issue an updated Form CRS when any information changes materially. NoteThe form can’t be longer than two printed pages, must be written in plain English, and must be presented to clients or potential clients before recommending any type of account, transaction, or investment advice involving securities. For example, here’s a Form CRS from T. Rowe Price Investment Services: The Balance The Balance Similar Disclosure Documents for InvestorsForm CRS isn’t the only advisor disclosure document available to investors.
Limitations of Form CRSForm CRS is helpful, but doesn’t give investors everything they need to know about an investment advisor. Even the SEC stresses that the form is simply a starting point for investors, who are encouraged to check regulatory actions and follow up with specific questions. While the form might disclose that conflicts of interest exist, it isn’t required to explicitly describe them. NoteThe SEC itself has found many Form CRS submissions to be inadequate, pointing out that some were confusing, poorly written or lacked some disclosures. By the middle of 2021, the SEC had penalized more than two dozen firms for failing to file Form CRS, assessing penalties of more than $97,000 in some cases. The Consumer Federation of America has complained that Form CRS, “does more to obscure than to clarify important differences between brokers and advisers and thus does not support an informed selection among different types of investment professionals.” Alternatives to Form CRSThere are some other ways to check out a financial advisor beyond Form CRS.
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