Depending on a firm’s size, preparing Form CRS, the Customer Relationship Summary to be delivered to retail customers under the Securities and Exchange Commission’s advice-standards package, will require a very different approach.
At Wells Fargo Advisors, it’s been a “collaborative effort,” with “a lot of input across business units,” Rema Holland, first vice president, account management strategy at Wells Fargo Advisors, said Wednesday during a panel discussion at the Financial Industry Regulatory Authority’s Regulation Best Interest conference in Washington.
Holland stated that there’s “a lot of information to put in four pages; people are editing each other’s edits” so that Wells Fargo can “agree on [a form] that is brief, educational and understandable.”
Wells Fargo Advisors is on its “third version” of Form CRS, she said, assessing design, accuracy, etc. “We’ve had clients, advisors and prospects work on it.” The firm is targeting the beginning of 2020, she said, to have a form “locked down.”
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On the other end of the spectrum, Wendy Lanton, a founding principal of broker-dealer Lantern Investments and Lantern Wealth Advisors, an SEC-registered investment advisor, says she’s the “only one” at her small firm wearing the Form CRS hat.
Lanton’s approach “vastly differs” from Wells Fargo’s, as “there isn’t a committee; it’s just me,” she told the packed room. One recent decision Lanton had to make, she relayed, is whether she needs to prepare one Form CRS or two because “we have an RIA affiliate.”
Alicia Goldin, an attorney at the SEC, stated on the panel that as the recent FAQ on Form CRS released by the agency stated, Form CRS is a “firm-level” document.