On June 19, 2020, the Oklahoma Department of Securities announced the withdrawal (effective immediately) of its recent requirement that state registered investment adviser firms must file the Form CRS/Form ADV Part 3 relationship summary as part of the Form ADV filing.
The State of Oklahoma’s Department of Securities originally provided notice on May 7, 2020 that investment adviser firms registered with the State of Oklahoma must file the Form ADV Part 3/Form CRS before June 30, 2020. (For more details about the initial regulatory requirement by Oklahoma Department of Securities to file the Form CRS/Form ADV Part 3 relationship summary, please click here.)
This subsequent amendment withdrawing the Form CRS/Form ADV Part 3 relationship summary filing requirement for Oklahoma state registered investment adviser firms did not include an explanation as to the reasons for its reversal.
Although the Oklahoma Department of Securities is apparently withdrawing its required filing of the Form CRS/Form ADV Part 3 relationship summary, the chairman of the U.S. Securities and Exchange Commission, Jay Clayton, reaffirmed last week that the compliance date the Form CRS/Form ADV Part 3 for SEC registered investment adviser firms is still June 30, 2020.
For further assistance determining whether your SEC registered investment adviser firm is required to deliver a Form ADV Part 3/Form CRS relationship summary, you can visit our Form ADV Part 3 FAQs website page here.
For SEC registered investment adviser firms with retail investors, RIA Compliance Consultants is hosting a webinar, “Compliance with Form ADV Part 3 Requirements,” on Wednesday, June 24, 2020. During this online compliance training event, we will discuss the initial delivery requirements to existing clients, the use of electronic delivery, the requirement to post to the website and hyperlinking to Form ADV Part 2A, the obligations to update, file and deliver after material changes and SEC examination issues. Click here to purchase your seat to this webinar.
If your investment adviser firm is an existing client of RIA Compliance Consultants and would like assistance in preparing/filing the Form CRS/Form ADV Part 3 relationship summary by June 30, 2020 or developing customized policies and procedures and/or IAR training regarding filing, updating and delivery of the Form CRS/Form ADV Part 3 relationship summary, we encourage you to speak with your compliance consultant. Or, if you are not an existing client of RIA Compliance Consultants, click here to set up an introductory call with our Business Development Team.