John Baker begins his discussion on Form CRS. He notes that it applies to SEC-registered investment advisers and broker-dealers. John adds that there is a 2-page limit, whereas dual registrants have 4 pages to work with. There are also a number of requirements and conditions regarding the format of Form CRS, such as use of white space, tables, charts, font size, etc. Layered disclosure is possible.
George Michael Gerstein advises financial institutions on the fiduciary and prohibited transaction provisions of ERISA. As co-chair of the fiduciary governance group, he assists clients with tracking, and understanding, the numerous fiduciary developments at the federal and state levels, including the rules and regulations of governmental plans. He also advises clients with respect to the fiduciary duty implications of ESG investing.