OFFICE OF COMPLIANCE BEGINS NEW PROCESS

In July 2020, the Office of Compliance Inspections will begin examinations to assess compliance with Form CRS. On July 27 2020, the SEC Staff Standards of Conduct Implementation Committee began reviewing relationship summaries from a cross-section of firms to assess compliance with the content and format requirements of Form CRS.  However, the Committee’s initial reviews have identified examples that may lack certain disclosures or could be clearer or otherwise improved. Particular firms may need to consider ways to improve their relationship summaries and determine whether any specific amendments, or broader change in their overall approach, would be appropriate. To provide an additional opportunity to share best practices and general feedback, the Committee plans to host a roundtable this fall where Commission staff will be able to share additional thoughts following the Committee’s review of firms’ initial relationship summaries.