Form CRS (SEA Rule 17a-14)
Quick Answer
Form CRS under SEA Rule 17a-14 is a plain-English relationship summary delivered to retail investors so they can compare firms. It covers services, fees, conflicts, standards of conduct, and disciplinary history in two pages for a BD or IA alone, or four pages for a dual registrant. Delivery triggers include recommendations, orders, account openings, rollovers, and requests.
Reg BI raises the conduct standard. Form CRS (the "customer relationship summary"), codified at SEA Rule 17a-14, raises the disclosure standard. It is a short, plain-English summary delivered to retail investors so they can compare firms and understand the relationship they are entering.
What is Form CRS?
- A relationship summary describing the firm's services, fees, conflicts, standard of conduct, and disciplinary history
- Written in plain English
- Filed with the SEC (broker-dealers via WebCRD, investment advisers via IARD)
- Posted prominently on the firm's public website, if one exists
Who Receives It: "Retail Investor"
A retail investor under Form CRS is a natural person (or the legal representative of a natural person) who seeks to receive or receives services primarily for personal, family, or household purposes.
Exam Tip: Gotchas
- "Retail investor" under Form CRS is broader than "retail customer" under Reg BI. A prospect who has not yet received a recommendation is still a retail investor for Form CRS delivery purposes, but is not yet a retail customer for Reg BI purposes. Form CRS gets delivered before Reg BI applies.
What are the Form CRS format and page limits?
Page limits are strict.
| Registrant Type | Page Limit (Paper Format) |
|---|---|
| Broker-dealer alone | Not more than 2 pages |
| Investment adviser alone | Not more than 2 pages |
| Dual registrant combining both services in one summary | Not more than 4 pages |
A dual registrant may, alternatively, prepare two separate 2-page summaries (one for brokerage, one for advisory).
What are the five required sections of Form CRS?
| # | Section | What It Covers |
|---|---|---|
| 1 | Introduction | Identifies the firm and the type of registration (BD, IA, or both) |
| 2 | Relationships and Services | What the firm offers, how it is paid, what limits apply |
| 3 | Fees, Costs, Conflicts, and Standards of Conduct | Material fees and costs, principal conflicts, and the standard of conduct the firm owes |
| 4 | Disciplinary History | Whether the firm or any of its financial professionals has reportable legal or disciplinary history |
| 5 | Additional Information | Where to find more detail (phone, website, the investor.gov/CRS resource) |
Each section uses "conversation starters" - standardized questions the form tells retail investors they can ask the firm. These are printed in bolded text so the customer can see them.
When must Form CRS be delivered?
Delivery is driven by the type of investor and the event.
New Retail Investor
Before or at the earliest of:
- Recommending an account type, a securities transaction, or an investment strategy
- Placing an order
- Opening a brokerage account
Existing Retail Customer: New or Different Account
Before or at the time the different account is opened.
Existing Retail Customer: Rollover Recommendation
Before or at the time of the recommendation to roll over retirement assets. This is its own separate trigger, even if no new account is opened.
Existing Retail Customer: New Service or Investment Without New Account
Before or at the time of the recommendation of the new service or investment (for example, a new brokerage service or investment that would not be held in an existing account).
Upon Request
Within 30 days of any retail investor's request.
Exam Tip: Gotchas
- Form CRS delivery on a ROLLOVER recommendation is a recurring exam point. Recommending that a customer roll retirement assets into a new or existing account triggers CRS delivery separately from any new-account opening. If the rollover is the only event, it still triggers delivery.
What are the Form CRS amendment and communication deadlines?
| Event | Deadline |
|---|---|
| File and post updated Form CRS whenever information becomes materially inaccurate | Within 30 days |
| Communicate amendments to existing retail customers | Within 60 days, without charge |
Think of it this way: The firm has a quick clock to fix the public-facing CRS (30 days to refile and repost) and a slightly longer clock to reach every existing retail customer with the updated version (60 days, free). Both clocks run in parallel.
Where must Form CRS be filed and posted?
- File the initial Form CRS with the SEC using the correct filing system (WebCRD for BDs, IARD for IAs)
- Post the current Form CRS prominently on the firm's public website, if one exists
- If the firm has no public website, it must still deliver to retail investors per the triggers above
What does Form CRS NOT do?
- Form CRS is a summary, not a contract
- It does not create a new legal relationship
- It describes the relationship the customer is entering and points to where more information can be found
Exam Tip: Gotchas
- Form CRS is a summary, not a contract. It describes the relationship; it does not alter it. A retail investor who receives Form CRS and then opens an account has not signed a new agreement just by receiving the form.
What are the most tested Form CRS requirements?
Exam Tip: Gotchas
- Page limits: 2 pages (BD or IA alone); 4 pages (dual registrant combined summary).
- Five sections: Introduction, Relationships and Services, Fees/Costs/Conflicts/Standards, Disciplinary History, Additional Information.
- Delivery triggers for new investors: the earliest of a recommendation, an order, or account opening.
- Rollover recommendation triggers CRS delivery on its own.
- Upon request window: 30 days.
- Amendment filing: 30 days. Customer communication of amendments: 60 days, no charge.
- Retail investor (Form CRS) is broader than retail customer (Reg BI) - prospects count.