RiXtrema’s Regulation Best Interest researchers created this checklist to get your gears turning toward compliance. It is not a substitute for consulting a legal or regulatory compliance office, but we feel it’s a suitable starting point. You must file the CRS Form with the SEC and freely provide it to all of your firm’s customers and clients by June 30, 2020. The CRS Form is essentially the 8 parts below. Before filing ask yourself whether each section in your form contains the outlined components.
☐ The name of the BD or RIA, and whether the firm is registered and with whom;
☐ an explanation as to how BD and RIA services and fees are different and how retail investors can understand the difference;
☐ free and simple research tools to investigate firms and financial professionals at the Commission’s investor education website (investor.gov/CRS);
☐ a list of tools that can guide the client to research firms and financial professionals
- Description of relationships and offered services:
☐ a list of all services and advice offered by the firm, even if the investor does not qualify for some products
☐ all relationships with the services offered to retail investors
- A statement of the applicable conduct standard associated with the services:
☐ Do you provide an example of how the firm makes revenue and any relevant conflicts of interest to do so?
- Fees and Costs:
☐ Do you describe the fees and costs associated with BD and RIA accounts and the conflicts they create?
- A Comparison of BD and RIA services for firms that are not dually registered:
☐ Do you state where retail investors can search for more information about their BD and RIA services?
- Conflicts of Interest associated with the firm’s relationship to its services, fees, and other BDs and RIAs.
☐ Do you disclose conscious and unconscious conflicts of interest?
- Legal and disciplinary events:
☐ Do you disclose whether your firm has any history of disciplinary action?
☐ Do you provide information, like tools or sources, to guide investors who want to research any events further?
- A list of prescribed “conversation starters” for investors to ask?
☐ Do you have answers prepared for the questions, if a retail investor asks?
☐ Are the questions prominently displayed with larger fonts, different typeface, bold, etc.?
The SEC requires the following questions to be included in this section:
- What is your relevant experience, including your licences, education and other qualifications? What do these qualifications mean?
- Help me understand how these fees and costs may affect my investments. If I give you $10,000 to invest, how much will go to fees and costs, and how much will be invested for me?
- How will you choose investments to recommend to me?
- Given my financial situation, should I choose an investment advisory service? Why or Why not?
- How might your conflicts of interest affect me, and how will you address them?
- As a financial professional, do you have any disciplinary history? For what type of conduct?
- Who is my primary contact person? Is he or she a representative of an investment advisor or broker-dealer? Who can I talk to if I have concerns about how this person is treating me?
☐ Is your final CRS Form two-pages (four pages for dual registrants)?
☐ Is your document delivered in plain language and shows it considers the retail investor’s level of financial knowledge?
☐ Do you have a filing process that will provide the form to the SEC before June 30, 2020 and keep it updated?
Contact us at firstname.lastname@example.org to receive a free eBook. Our Reg-BI eBook is a comprehensive guide written to inform you about all the components of Reg-BI in just 20 minutes.
For any questions related to Regulation Best Interest or RiXtrema’s Financial Planning Software Platform please contact:
Luke St. Angelo
Sr. Executive, Client Success
Digital Content Strategist