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Although most advisors seem to have filed their Customer Relationship Summary form, known as Form CRS, by the Securities and Exchange Commission's June 30 deadline, some stragglers remain, according to Chris DiTata, RIA in a Box vice president and general counsel.
"The vast majority of firms that we work with have done it timely [and] I would expect that is the same for the broader industry," he told ThinkAdvisor in a recent phone interview.
There are, meanwhile, six facts around Form CRS that advisors should continue to keep in mind, he said:
1. Late Filers
"The only firms that might be filing late are those firms that didn't have retail clients but are looking to take on retail clients now," DiTata said, adding: "The trigger for firms that haven't taken on retail clients is basically meeting with retail prospects." So, if you have started speaking to a retail client, it's time to file a Form CRS.
2. Making Edits
Among advisors who filed on time, "we have seen some firms that have already made edits to their Form CRS to disclose new fee structures, new conflicts of interest and other pertinent details," DiTata noted.
The RIA compliance software provider has helped advisor clients make edits to the form, most of them after June 30, he pointed out, but added it's only been a "single-digit percentage" of clients who had done that so far.
Edits are "definitely allowed and encouraged," he said, adding: "When the Form CRS changes in a material manner, you need to update it."
3. SEC Roundtable
"To provide an additional opportunity to share best practices and general feedback," the SEC said it "plans to host a roundtable this fall where SEC staff "will be able to share additional thoughts following the Committee's review of firms' initial relationship summaries."
