On April 6, 2020, the SEC released updated Form CRS FAQs. Among other things, the FAQs address the following aspects of filing Form CRS:
- Form CRS/ADV Part 3 filing started April 6 – Firms were able to begin filing the form on April 6. Broker-dealers are able to file through Web CRD and investment advisers through IARD. Any dual-registered firms attempting to file through Web CRD will be automatically redirected to IARD.
- Process for dual registrants to file Form CRS – Dual-registered firms should file a single PDF file containing their broker-dealer Form CRS and their investment adviser Form CRS (whether prepared as a combined four-page relationship summary or separate two-page summaries), along with any applicable exhibits created for filing purposes.
- Process for broker-dealers with affiliated investment advisers to file their Form CRS – Broker-dealers who are affiliated with an investment adviser may draft a combined Form CRS. In this instance, the affiliate would still have the responsibility to file the Form CRS separately.
Firms should start drafting their forms for filing as soon as possible. Although the June 30, 2020 deadline is more than two months away, there is still a level of effort needed to determine what information should be included in the form and what supplemental disclosure documents should be prepared.
How ACA Can Help
ACA can assist firms with the preparation and filing of Form CRS. Please contact your ACA Consultant or Dee Stafford to find out about ACA's filing services.