Mrs. Robinson is late again. Normally, this wouldn’t be concerning, but she missed her last meeting without any notice. She’s a sweet lady, recently widowed, and having patience with her is easy with that warm smile she has. After 15 minutes, you just surmise that she is not going to make it in today. Again. You feel the need to look out the front door of the office building on the off chance that she is pulling into the parking lot. As you walk down the hallways of your offi
Welcome back! To wrap this up, we will discuss the final three Items that go on the ADV Part 3 aka Form CRS aka the “Not More Paperwork” form. We left off at Item 6 titled “Conflicts of Interest.” Under this heading you will need to include the phrase, “We benefit from the advisory services that we provide to you” followed by a brief description of those conflicts that may apply to you, such as sharing revenue with a third party or acting as a principal. Following the Conflic
In our last post, we started you on a long journey discussing the requirements of the proposed Form CRS. We are going to pick up where we left off with the Standard of Conduct, Fees, and Firm Comparison sections. As you’re reading along, remember this whole document needs to be kept to 4 or fewer pages. Item 3, addresses Standard of Conduct. You will need to add the heading “Our Obligations to You,” and the section will need to include the following disclosure, “We must abide
We want to begin this post at the beginning. At first glance, you can see some of the similarities between the Brochure (ADV Part 2) and the Form CRS. While one glaring difference is that the Form CRS is also required for Broker-Dealers, this post will focus on the proposed requirements for Investment Advisers. Item 1: You should state your name and indicate whether you are an Investment Adviser registered with the Securities Exchange Commission or a state commission. If you
Form CRS: The Devil is in the Details Last week we had an introduction to the Form CRS (the ADV Part 3) which is proposed in a recent SEC IA release. The purpose of this form is to simplify disclosures, so clients can easily understand the important information in order to make a sound decision with their finances. Under the SEC proposal, advisers will be required to deliver a relationship summary to their clients. This week we are going to dive into the details of this form.
This month the Securities Exchange Commission published a proposal (IA-4888) for additional regulations for Broker/Dealers and Investment Advisers. Over the next few weeks, we will break this down so it can be more easily digested and not so frustrating for you. It feels like there’s a constant stream of new regulations and amendments that we must deal with, but with a little guidance, we can find simple solutions to these complex problems. IA-4888 was published this month wi