Oklahoma has changed its mind about requiring state-registered advisers to file a client relationship summary that has been mandated for federally registered advisers.
The state was one of two, along with Rhode Island, that expected its advisers to file the Form CRS by June 30, the date when the Securities and Exchange Commission’s investment advice reform regulatory package went into force.
The disclosure document -- which outlines a firm’s services, fees, conflicts of interest, standard of conduct and disciplinary history, among other information -- is mandatory for SEC advisers and for brokers.
But it was up to each state to decide whether to impose a similar requirement on state advisers.
Oklahoma rescinded the Form CRS requirement for the approximately 182 state-regulated advisory firms after receiving complaints from advisers and industry representatives, said Melanie Hall, administrator of the Oklahoma Department of Securities.
“We’re reviewing it to see if there’s any benefit to their clients for that additional disclosure to be made,” Hall said. “Right now, it’s on hold.”
Rhode Island has no plans to remove its Form CRS requirement for the approximately 70 advisory firms it regulates.
Don DeFedele, associate director for securities and commercial licensing at the state’s Department of Business Regulation, said Form CRS enhances disclosure and does a good job of outlining what clients can expect from an adviser.
“There’s good information in here,” DeFedele said. “This, to me, is more plain-English type of stuff. I don’t think it’s an onerous request for IAs, and it’s helpful for clients.”
The North American Securities Administrators Association told the SEC it did not conduct appropriate investor testing for Form CRS and that it is duplicative of information already recorded in the adviser registration document known as Form ADV.
Most states have not imposed a Form CRS requirement on their advisers. But it’s difficult to know how many have done so or may be considering it.
“Now that Form CRS is live, I think some states are taking another look at it,” said A. Valerie Mirko, partner at law firm Baker McKenzie and former NASAA general counsel. “I would think they’re assessing if there’s value for state adoption.”
The SEC regulates investment advisers with more than $100 million in assets under management, while states regulate those below that threshold.
Advisers will have to deliver Form CRS to their clients by early August. DeFedele said Rhode Island will help them to achieve compliance.
“If somebody’s having some difficulty, we’ll work with them,” he said.
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