SEC Staff Publishes Statement Regarding Form CRS Disclosures

On December 17, 2021, the U.S. Securities and Exchange Commission ("SEC") staff ("Staff") issued a statement (the "Statement"),¹ which summarizes certain observations made by the SEC's Standards of Conduct Implementation Committee (the "Committee") in connection with its review of Form CRS relationship summaries ("relationship summaries") filed by a cross-section of firms and their compliance with Form CRS requirements. The Committee observed various areas where improvements are needed with respect to both the content of the disclosures and the format of the form itself.² Among the Committee's observations included:

• firms are not permitted to include disclosures in the relationship summary beyond those that are required or permitted by the Form CRS instructions;