OCIE issued a Risk Alert to provide broker-dealers and investment adviser with information about the scope and content of initial examinations after the compliance date for Form CRS. The Risk Alert indicates that initial examinations will focus on assessing whether firms have made a good faith effort to implement Form CRS and highlights the following areas:
- Delivery and filing – OCIE may review whether a firm has appropriately filed and delivered its Form CRS. In particular, OCIE may review records of the dates that each relationship summary was provided to retail investors to validate whether the firm has complied with the delivery obligations.
- Content – OCIE may review content, including the areas prescribed in the instructions to Form CRS.
- Recordkeeping – OCIE may review the firm’s records related to delivery of the relationship summary, and the policies and procedures regarding such records.
The Risk Alert also highlights that OCIE may, over time, review whether a firm appropriately updates its Form CRS.