Reality Check: Form CRS Failures and SEC Enforcement Actions

Reality Check: Form CRS Failures and SEC Enforcement Actions

Last week, the SEC charged 27 financial firms for missing regulatory deadlines pertaining to filing and delivering Form CRS.

As a recap, the SEC adopted Form CRS on June 5, 2019. The deadline for SEC-registered investment advisers and broker-dealers to file and start delivering Form CRS was June 30 for prospective and new retail investors and July 30 for existing retail investor clients—of LAST year. Firms with a website were also required to prominently display their current Form CRS online.

Despite being reminded twice of the missed deadlines, the firms charged last week failed to file, deliver, and post their Form CRS—eventually prompting enforcement actions by the SEC.

These actions are a reminder to take the SEC’s regulatory deadlines and reminders seriously. In a blog post published last year, we gave 10 tips for completing Form CRS in a timely manner.

We realize it’s a challenge to implement new regulatory policies and to file and deliver new forms, especially for smaller firms with limited resources. But the SEC isn’t going to let you off the hook because it’s hard. Joot’s compliance experts have completed numerous Forms CRS and other required filings for our clients. If you need help meeting regulatory deadlines or improving your RIA compliance program, please get in touch.

Also, Joot's blog focuses on helping RIA firms understand the range of regulatory obligations they’re required to meet as part of their fiduciary duty. For example, check out our blog post series on the new SEC marketing rule for down-to-earth advice on rule interpretation and implementation.

And remember, if the SEC reminds you to complete a regulatory obligation, make sure you act promptly!