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Vedder Thinking | Articles SEC Charges 12 Additional Firms for Failure to Meet Form CRS Obligations


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On February 15, 2022, the SEC announced settlements with 12 firms—six investment advisers and six broker-dealers— relating to the alleged failure to (1) file and deliver Form CRS relationship summaries to their retail clients by the required deadline and, in certain cases, (2) include all information necessary to satisfy Form CRS requirements. The SEC’s press release noted that a total of forty-two firms have now settled administrative proceedings with the SEC for alleged failures to satisfy Form CRS filing, delivery and/or content requirements since the Form’s requirements took effect (June 30, 2020 with respect to prospective and new retail clients and July 30, 2020 with respect to existing retail clients). In the latest batch of settlements, each of the firms agreed—without admitting or denying the SEC’s findings— to be censured, to cease and desist from violating the charged provisions and to pay civil penalties ranging from $10,000 to $97,523.

The settlements follow a December 2021 statement issued by the SEC’s Standards of Conduct Implementation Committee, summarizing its observations following a review of Form CRS relationship summaries filed with the SEC by a cross-section of broker-dealers and investment advisers and the firms’ compliance with Form CRS requirements. (See SEC Staff Statement Highlights Need for Form CRS Disclosure Improvements, available here.)

The SEC’s press release announcing the settlements is available here.


Christina V. West


John S. Marten


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Jacob C. Tiedt