Investment Advisers registered with the SEC are required to file with the SEC and deliver to retail investors a relationship summary disclosing certain information about the firm. Currently registered firms and those with pending SEC registrations must file Form CRS Relationship Summary by June 30, 2020.
If you do not have any retail investors to whom you must deliver a relationship summary, you are not required to prepare or file one. Please see the Form CRS Relationship Summary Delivery FAQ for the definition of retail investors. Beware that individuals with high net worth are retail investors for Form CRS purposes, while organizations (e.g. hedge funds, private equity funds, venture capital funds, family offices) are not retail investors.
State-registered Investment Advisers should check state regulations on whether a similar filing is required.
GACS Form CRS Relationship Summary Drafting Guide and Samples are meant to offer guidance and assist Firms as they prepare their initial Form CRS Relationship Summary. The guidance does not constitute legal advice and Firms should consult with their legal counsel as needed. Please contact us if you have any questions with respect to Regulation Best Interest and Form CRS or would like assistance drafting an initial relationship summary.
Greenwich Advisor Compliance Services can also assist with reviewing and updating your compliance policies and procedures. You can ask us a compliance question here.
For more information about Form CRS, please visit here for instructions and here for FAQ.