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On February 18, 2021, EXAMS again contacted SFA but this time to announce an examination relating to the firm’s failure to file Form CRS. SFA finally filed Form CRS with the Commission on February 25, 2021, and the firm did not deliver Form CRS to its existing retail investor clients until March 2, 2021. In addition, SFA failed to post Form CRS on its website until March 2021
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