Content Level: Foundational
NAPFA Subject Area: A-Financial Planning Process

The 2019 the SEC Interpretation for Investment Advisers and Form CRS Rule significantly increases the scope and detail required for disclosures of conflicts of interest. The Form CRS creates a new disclosure document for investment advisers, also known as the Form ADV Part 3. Although the Form CRS requirement will not apply until June 30, 2020, the Form CRS must be provided to clients by all existing and prospective “retail investors,” which is broadly defined as any individual investor. Many investment advisers are struggling to complete the Form as required.

1. New Interpretations and rules for disclosures
2. Conflicts of interest
3. Duties of loyalty and care

C. Fred Reish