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The Institute for the Fiduciary Standard

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SEC Investor Roundtables Reveal Investors Often Do Not Understand Form CRS

By Darren Fogarty on September 17, 2018

On April 18, 2018, the Securities and Exchange Commission (SEC) released a proposed Form CRS Relationship Summary that aims to increase clarity of investment professionals’ business models for investors. Form CRS is a hypothetical 4-page disclosure document that highlights the differences between broker dealers and registered investment advisors.

SEC Chairman Jay Clayton has set a high standard for Reg BI and Form CRS. He has said they should match reasonable investor expectations, maintain choice, address investor confusion, and offer “clear answers.” Does Form CRS meet this standard?

The SEC’s investor roundtables suggest the answer is, “no”. Even highly educated investors with careers in the financial, legal, and writing professions say the language in Form CRS is “poorly written,” “ambiguous,” and “need[s] more clarity.” Lawyers have difficulty making sense of it.

Assistant Director to the SEC’s Investment Adviser Regulation Office, Sara Cortes says, “[Y]ou need to tell people about [your conflict], and you need to tell people about it in a way…that’s sufficient that they can understand it.”1 41% of investors who spoke at the largest Investor Roundtable expressed dissatisfaction, views suggesting that Form CRS did not meet this standard. This whitepaper contains excerpts from all six roundtables of ordinary investors objecting to how Form CRS is written.

Download the full copy of the whitepaper here, or below.

Dan Moisand

 

Dan Moisand is a nationally recognized fiduciary fee-only financial planner, an Institute Real Fiduciary™ Advisor and Chair-elect of the CFP Board.

The Institute has enshrined the ‘Moisand Rule’ on fiduciary practices. It is basic and is more important today than ever: “You have to avoid conflicts. If I avoid a conflict, I don’t worry about it.”

Watch the video of Moisand speaking here.

Bob Veres

 

Bob Veres is a long term observer of financial planning. His Newsletter, “Inside information” Is a staple of leading planners. In the May edition he writes about fiduciary and the Institute.

"But a much bigger point is that the fiduciary standard—as Knut Rostad of the Institute for the Fiduciary Standard has pointed out—has been determined by the Supreme Court (1963 ruling) to be at the very heart of the Investment Advisers Act of 1940. It is the foundation of what it means to be an RIA registered with the SEC instead of a tipster or a tout."

- Bob Veres, Parting Thoughts ... The SEC's Own Compliance Culture

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