By Buddy Doyle
Reg BI and Form CRS: Compliance Still Expected by June 30, 2020
Reg BI Update – SEC Warns that “firms should continue to make good faith efforts around operational matters to ensure compliance by June 30, 2020”
With so many firms changing how they serve their retail clients during the COVID-19 outbreak, the SEC issued a Public Statement on April 2nd related to Regulation Best Interest (“Reg BI”), and the Form CRS requirements. The statement, authored by Chairman Jay Clayton, stated, “we believe that the June 30, 2020 compliance date for Reg BI and other requirements, including the requirement to file and begin delivering Form CRS, remains appropriate.”
While this statement may come as a surprise to some CCOs, it is certainly not too late to be compliant by June 30. But you need to get started soon to be sure you meet the deadline. There are a number of tasks to be done to fully implement a well-organized and efficient Reg BI Compliance Program and thoughtful disclosures. In times of extraordinary volatility litigation risk is higher, and having clear disclosures about how you serve your clients can lead to a common understanding that mitigates the risk of regulatory actions and customer complaints.