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ARTICLE · 05 AUGUST 2021

SEC Charges 21 Advisers For Form CRS Failures – Impact On Private Fund Managers

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On July 26, 2021, 21 investment advisers entered into settlements with the Securities and Exchange Commission to resolve charges that they failed to timely file and deliver their relationship summaries...

United StatesFinance and Banking
Peter I. Altman
Peter I. Altman
Michael Asaro
Michael Asaro
Brian T. Daly
Brian T. Daly
Jason M. Daniel
Jason M. Daniel
Alexandra L. Delman
Alexandra L. Delman
Barbara Niederkofler
Barbara Niederkofler
Douglas Rappaport
Douglas Rappaport
Stephen Vine
Stephen Vine
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On July 26, 2021, 21 investment advisers entered into settlements with the Securities and Exchange Commission to resolve charges that they failed to timely file and deliver their relationship summaries on Form CRS.1 Penalties ranged from $10,000 to $97,523 per firm.

Form CRS, adopted by the SEC on June 5, 2019, is a "relationship summary" that registered investment advisers were initially required to deliver to retail investor clients (and prominently post on their websites) by June 30, 2020. According to the SEC's orders, each of these 21 firms missed that deadline-notwithstanding an April 7, 2020, Risk Alert.2

In light of these charges and settlements, legal and compliance personnel of private fund managers and sponsors should confirm that they are in compliance with any Form CRS obligations, and consider specific steps such as the following:

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