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What Form CRS is
Form CRS is a two-page (or four-page for dual-registrants) relationship summary required under SEC rules. It uses a fixed structure with prescribed headings — Introduction, Relationships and Services, Fees, Conflicts of Interest, Disciplinary History, and Additional Information. Plain English is mandatory; no jargon, no marketing.
Form CRS is filed as Form ADV Part 3 for advisers, alongside the firm's Part 1A registration and Part 2A brochure.
Who must deliver it
Any firm that has retail investors as clients — defined as natural persons receiving recommendations or services for personal, family, or household purposes — must deliver Form CRS. Pure institutional firms with no retail clients are exempt.
- Initial delivery: at the start of a new retail relationship, or before any recommendation is made.
- Triggered redeliveries: when there's a material change, when a new account type is opened, or when the customer requests it.
- Ongoing availability: posted on the firm's public website.
What examiners check
SEC and FINRA examinations consistently flag three Form CRS deficiencies:
- Late or missing initial delivery — no record showing the customer received the summary before the recommendation.
- Stale content — disciplinary disclosures or fee schedules that don't match current Part 1A or Part 2A.
- Non-compliant language — marketing-style claims, omitted required headings, or content that conflicts with the firm's brochure.
Form CRS and Reg BI together
Form CRS is the disclosure pairing for Regulation Best Interest. Reg BI sets the standard of conduct; Form CRS communicates the relationship to the customer. Delivering Form CRS does not satisfy Reg BI's separate Disclosure Obligation — it is one input among several.
How StratiFi thinks about Form CRS
The firms that handle Form CRS well treat it as a living artifact, not a once-at-onboarding form. Every change to fees, services, conflicts, or disciplinary history triggers a redelivery decision. When the disclosure system, the brochure, and the recommendation log are connected, the question "did the customer receive an accurate Form CRS before this recommendation?" has a defensible answer for every account.
Frequently asked questions
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When did Form CRS become required?
Form CRS took effect June 30, 2020, alongside Regulation Best Interest. Firms have been required to deliver it to retail investors since that date. -
Does Form CRS apply to institutional clients?
No. Form CRS is required only for retail investors — natural persons using services for personal, family, or household purposes. Pure institutional firms are exempt. -
How is Form CRS different from the Form ADV brochure?
The brochure (Part 2A) is a longer narrative document about the firm. Form CRS (Part 3) is a short, plain-English relationship summary with a prescribed format. Both are typically delivered together to a new retail client.