Record when Form CRS was delivered to a retail investor
Key facts
- Human involvement
- YellowClose supervision
- How AI is used
- From the account file, record the date the current Form CRS was delivered, and the dates of any recommendation of an account type, a securities transaction, or an investment strategy involving securities, any order, and any opening of a brokerage account. For an existing customer, record any new account that differs from the existing account, any recommendation to roll over assets from a retirement account, and any new brokerage service or investment. Do not decide that delivery was timely.
- What the lawyer must review
- The lawyer applies 17 CFR 240.17a-14, the broker-dealer Form CRS rule. The section applies to every broker or dealer registered under section 15 of the Exchange Act that offers services to a retail investor. The broker-dealer must deliver the current Form CRS before or at the earliest of a recommendation of an account type, a securities transaction, or an investment strategy involving securities; placing an order for the retail investor; or the opening of a brokerage account. For an existing customer, delivery is required before or at the time the firm opens a new account that is different from the existing account, recommends a rollover of assets from a retirement account into a new or existing account or investment, or recommends or provides a new brokerage service or investment that does not necessarily involve opening a new account and would not be held in an existing account. Changes are communicated to each existing retail customer within 60 days after the amendments are required to be made, and without charge. A current Form CRS is delivered within 30 days upon request. Delivery under this section does not relieve other disclosure obligations. The eCFR page states the same initial delivery points. The investment-adviser Form CRS rule was not the section opened.
- Written for / version
- United States versionUS
Who does what
| Role | What they do |
|---|---|
| Assistance | Do not begin AI assistance until the responsible lawyer has defined and confirmed its permitted scope. |
| Lawyer | Set the scope, supervise the work closely, verify every part relied on, resolve omissions and exceptions, and approve the exact output. |
Checklist
- Check the current court or regulator requirements, prescribed form and attachments for the intended document and filing.
- Obtain and inspect the relevant current official register or search result. Confirm identities, interests and the date and scope of the search.
- Verify the applicable jurisdiction and the version of each relevant law, rule or instrument in force at the material time.
- Confirm the output against the client’s instructions and the complete relevant source material, including omissions or contradictions.
- Resolve exceptions and record the responsible lawyer’s approval of the exact output and intended use.