What is the First Document SEC Examiners Read? Form CRS
Peter Driscoll, Director of the SEC’s Division of Examinations, told attendees at the Investment Adviser Association meeting March 4, 2021 that Form CRS is a priority for SEC examiners. Mr. Driscoll stated, “We identified hundred of firms that did not file Form CRS that we thought should have. A large number of those we contacted did not respond to us.” The Division is planning to open exams for the “hundreds” of firms who haven’t filed Form CRS and those that didn’t respond to SEC inquiries about the filing.
Mr. Driscoll, talking about the importance of Form CRS, said it is the first document examiners read, himself included. Then examiners “dig into Form ADV.”
Advisers and broker-dealers should take action regarding the heads up on what’s coming in their next exam by reviewing the accuracy of their firm’s Form CRS and tracking closely against the instructions and Form CRS FAQs.
We have an innovative technology tool that does just that—tracks to dozens of responses on a firm’s Form ADV or BrokerCheck as well as each requirement of the instructions and the FAQs. “There is no easier way to track the accuracy,” said Keith Marks, Executive Director of CSS. “Plan now for your Form ADV annual updating amendment and material changes to Form CRS.”
For more information on Form CRS or help preparing for an exam, email us at FormCRS@cssregtech.com.