RIA Disclosures: Form CRS/ADV Part 3, Share Class Disclosures, and More
Fred Reish, Partner, Faegre Drinker Biddle & Reath
April 21, 2020
The SEC has imposed new disclosure requirements on investment advisers with the new ADV Part 3, also known as the Form CRS. The 178 page regulation imposes strict requirements about the contents of the new form, which cannot be longer than 2 pages. It must be provided to all existing clients and new clients beginning June 30, 2020. In addition, the SEC has expanded its definition of conflicts and required disclosures for conflicts, for example, through the SEC SCSD Initiative and the Conflicts FAQs.