Drafting Tips for ADV Part 3/Form CRS

May 20, 2020

In June 2019, the U.S. Securities and Exchange Commission (“SEC”) adopted a new rule requiring SEC registered investment adviser firms to prepare and deliver an easily accessible and understandable Consumer Relationship Summary, also known as the Form CRS or Form ADV Part 3, to retail investor clients.

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NASAA Proposed Investment Adviser Representative Continuing Education Rule

May 11, 2020

Earlier this year, the North American Securities Administrators Association, Inc. (“NASAA”) proposed a new model rule that would require investment adviser representatives (“IARs”) to complete a specified amount of continuing education (“CE”) credits each year. The proposed model rule would apply to every IAR registered in a state that adopts the model rule, including IARs associated with state registered investment adviser firms. It would also cover IARs for federal covered advisers (i.e. SEC-registered advisers) to the extent that those IARs are registered in a given state.

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Oklahoma Requiring Submission of Form ADV Part 3/Form CRS

May 08, 2020

On May 7, 2020 the State of Oklahoma’s Department of Securities announced that investment adviser firms registered with the State of Oklahoma must file the Form ADV Part 3/Form CRS before June 30, 2020. Click here to read Oklahoma’s NOTICE TO INVESTMENT ADVISERS RE: FORM CRS. This is significant because Oklahoma is the first state securities regulator to require the filing of the Form ADV Part 3/Form CRS by a state-registered investment adviser firm. Previously, only SEC registered investment adviser firms with retail investors were required to file the Form ADV 3/Form CRS.

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Drafting Tips for an SEC Investment Adviser’s Form CRS/Form ADV Part 3 

May 07, 2020

In June 2019, the U.S. Securities and Exchange Commission (“SEC”) adopted a new rule requiring SEC registered investment adviser firms to prepare and deliver an easily accessible and understandable Consumer Relationship Summary, also known as the Form CRS or Form ADV Part 3, to retail investor clients. An SEC registered investment adviser’s initial Form CRS/Form ADV Part 3 must be filed with the SEC by June 30, 2020 and delivered to existing clients no later than July 30, 2020. Click here to read our recent blog on the SEC’s decision to maintain the original June 30, 2020 filing deadline.

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SEC Provides Investment Advisers Guidance on Disclosure of PPP Loan

May 04, 2020

The U.S. Securities and Exchange Commission (“SEC”) recently provided guidance on the disclosure obligations of an investment adviser firm when receiving a Paycheck Protection Plan (“PPP”) loan guaranteed by the U.S. Small Business Administration in conjunction with the relief afforded from the CARES Act during the COVID-19 pandemic.

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Drafting Tips for Form ADV Part 3/Form CRS

May 01, 2020

On June 5, 2019, the U.S. Securities and Exchange Commission (“SEC”) approved a rule requiring investment adviser firms registered with the SEC to provide investment advisory clients who meet the definition of “retail investors” with a Consumer Relationship Summary, also known as the Form CRS or Form ADV Part 3. Despite the impact of COVID-19, the SEC has declined to extend the deadline for investment advisers registered with the SEC to file and deliver the new Form ADV Part 3/Form CRS. Click here to read our recent blog on the SEC’s decision to maintain the original June 30, 2020 filing deadline.

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Preparing the Form ADV Part 3/CRS – FREE Compliance Training Webinar

April 21, 2020

On Wednesday, April 22 at 12:00 PM CT, RIA Compliance Consultants will host a webinar entitled, “Preparing the Form ADV Part 3/CRS.” During this webinar, Bryan Hill, President of RIA Compliance Consultants, Inc., will be discussing how to prepare the Form ADV Part 3/Client Relationship Summary for investment adviser firms registered with the U.S. Securities and Exchange Commission. The webinar will be hosted on Zoom.com.

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