Form CRS

Firm failed to disclose that it had a disciplinary history and omitted required "conversation starters" regarding fees and costs and conflicts of interest

So far so good except the firm erred in what it disclosed about the program

Although the adviser's policy required it to identify and disclose conflicts of interest, it lacked any written P&Ps to ensure that conflicts of interest around ...

Remedial actions taken by the firms include the hiring of new compliance professionals at senior levels with extensive broker-dealer and investment adviser experience

Form CRS enforcement actions continue to be brought as the industry approaches the five-year anniversary of the form's June 30, 2020 compliance date

WSPs discussed Reg BI in general terms, but did not drill down on certain specific provisions

ACP Securities didn't disclose employee's disciplinary history, FINRA claims

Vistia Capital did not timely amend its Form CRS to disclose that one of its financial professionals had disciplinary history as required

The case offers the lesson that you cannot leave sections of your WSPs essentially blank

Reg BI and Form CRS failures lead to penalty for Texas-based broker-dealer