The SEC staff has issued a statement that its Standard of Conduct Implementation Committee is reviewing Form CRS filings and will “engage with firms” about how to improve the disclosure. The Committee’s initial reviews, while identifying good examples of clear disclosure, have also revealed Forms that lack required disclosures or could otherwise be improved. The Committee will communicate recommended changes to affected firms. The staff also plans to host future best practices roundtables.
The regulators are watching and reviewing. To our knowledge, the SEC hasn’t previously publicized the creation of this Committee or its mission or activities. Will the Committee make referrals to Enforcement? Will it draft more FAQs? Regardless, the Committee should make less serious firms take notice that the SEC is watching and reviewing the Form CRS filings.