Form CRS for Advisors: What It Is, Who Files It, and What Changes When You Move

The short answer: Form CRS is the relationship summary that every SEC-registered broker-dealer and investment adviser with retail clients must file, post on its website and give to those clients. It runs two pages on paper, answers five items in a fixed order, and tells the client what the firm offers, what it costs, what conflicts it has, what standard of conduct applies and whether the firm or its people have disciplinary history. For an advisor, it matters most at three moments: joining a new firm, launching an RIA, and hiring someone whose record changes the firm's answers.

The relationship summary is the firm's document, which is why a move touches it. The new firm's summary is the one clients receive, a new hire can change what it must say, and an SEC-registered breakaway with retail clients writes its own before the first client signs. Our guide to what Form ADV asks of a new RIA covers the rest of the filing.

What Form CRS is, and who has to file it

The SEC adopted Form CRS on June 5, 2019, alongside Regulation Best Interest, with a compliance date of June 30, 2020. It applies to broker-dealers registered with the SEC and investment advisers registered with the SEC that serve retail investors. A retail investor is a natural person who seeks services primarily for personal, family or household purposes; there is no net worth or asset test, so a wealthy family counts the same as a first-time investor. A firm with no retail investors does not prepare one.

For an investment adviser, Form CRS is Part 3 of Form ADV, filed through IARD. A broker-dealer files it through FINRA's Web CRD. Once filed, it is public: it displays in BrokerCheck or the SEC's adviser database alongside the firm's other filings.

State-registered advisers have no federal Form CRS requirement. The Form ADV instructions say Part 3 applies to advisers registered or applying for registration with the SEC, and SEC staff have said the delivery requirements apply only to SEC-registered advisers. Rhode Island told its state-registered advisers in 2020 to file a Form CRS with Form ADV; a firm registered there should confirm with the state's Securities Division whether that still applies.

What goes in it: five items, two pages

The summary answers five items, in this order and no other:

1. Introduction. The date, the firm's name, whether it is registered as a broker-dealer, an investment adviser or both, and a pointer to Investor.gov/CRS.
2. Relationships and Services. Under the heading "What investment services and advice can you provide me?": the principal services, monitoring, investment authority, any limits on what the firm offers, and account minimums.
3. Fees, Costs, Conflicts, and Standard of Conduct. The principal fees and how often they are charged, other costs, the conflicts the firm's revenue creates, how its financial professionals are paid, and prescribed wording on the standard of conduct.
4. Disciplinary History. The heading "Do you or your financial professionals have legal or disciplinary history?" and a plain Yes or No.
5. Additional Information. Where to find more and how to request a copy, with a phone number.

On paper a broker-dealer's or adviser's summary may not exceed two pages, and a dual registrant that combines brokerage and advisory services may use four. The instructions require plain English, written as if speaking to the client, and bar boilerplate and unsupported claims. Items 2 through 5 carry required conversation starters, questions such as "How might your conflicts of interest affect me, and how will you address them?", which the client is invited to ask.

The standard-of-conduct wording differs by firm type. An adviser's summary says, in prescribed words, "When we act as your investment adviser, we have to act in your best interest and not put our interest ahead of yours." A broker-dealer's says the firm must act in the client's best interest when it provides a recommendation. That difference is the core of Reg BI versus fiduciary duty, and an advisor who moves from one kind of firm to the other will see it in the new firm's summary.

SEC staff have singled out the disciplinary answer in their guidance, and the Division of Examinations' fiscal 2026 priorities name it specifically. Firms may not leave it blank, narrow it to the firm alone, or add explanatory language to it. It is Yes if the firm or any of its financial professionals currently discloses, or is required to disclose, specified items on Form ADV, Form BD or the professionals' Forms U4, U5 or U6.

When clients receive it

The trigger depends on the kind of firm:

• An investment adviser delivers it before or at the time it enters into an advisory contract with the retail investor, even an oral one.
• A broker-dealer delivers it before or at the earliest of a recommendation of an account type, a securities transaction or an investment strategy, placing an order, or opening a brokerage account.
• A dual registrant delivers at whichever of those comes first.

Existing retail clients receive the current summary again before or when the firm opens a new account different from their existing ones, recommends a rollover from a retirement account, or recommends a new service or investment that would not sit in an existing account. Any retail investor can ask for a copy, and the firm has 30 days to send it. Electronic delivery is allowed under the SEC's electronic delivery guidance, provided the summary is presented prominently, for example as a direct link or in the body of an email; staff have said that making it available is not enough on its own.

When it has to be updated

A firm files an amended summary within 30 days whenever any information in it becomes materially inaccurate, with an exhibit highlighting what changed, and tells existing retail clients within 60 days after the update was required, either with the amended summary or through another disclosure. FINRA's exam reports describe that as 90 days in total from the date the summary became inaccurate. Changes that are not material do not have to be filed, but the posted version must stay current.

What changes when an advisor moves

Joining a firm. The duty sits with the firm. When an advisor joins and a client opens an account at the new firm, the new firm delivers its own summary under its own trigger: an adviser at or before the advisory contract, a broker-dealer at the earliest of a recommendation, an order or the account opening. For a client new to the firm, the initial delivery comes first; for a client who already has a relationship with the new firm, a recommendation to roll a retirement account into it brings its own delivery obligation. The new firm's summary is also where a client sees how the new firm is paid and the conflicts that creates, which is why the Form CRS of a firm an advisor is weighing is worth reading before the first meeting. The paperwork around it is covered in how client accounts move when you change firms.

A hire can change the firm's answer. Because Item 4 reaches the firm's financial professionals, hiring someone with reportable history on Form U4 can turn the firm's No into a Yes and start the 30-day amendment clock. In September 2024 the SEC charged two broker-dealers for not updating their summaries within 30 days after hiring a professional with reportable history; one hired in August 2021 and corrected its summary in October 2023, the other hired in July 2022 and updated in October 2023. What shows on an advisor's own record, and how it gets there, is explained in Form U4 vs Form U5.

Launching an RIA. A breakaway that registers with the SEC and will have retail clients files its own Form CRS with its initial application: the SEC "will not accept any initial application for registration" without one in that case. A firm that registers with its state instead files none under federal rules. Which registration applies depends on regulatory assets and the Form ADV exemptions, including a path for a newly formed adviser that reasonably expects to become eligible for SEC registration within 120 days. A state-registered firm that later moves to SEC registration files its summary with its SEC application; the delivery requirements begin once registration is granted, and staff would not object to delivery to existing retail clients within 30 days after the order granting registration takes effect. New firms also draw examiners' attention: the SEC's Division of Examinations says it prioritizes advisers never examined, with emphasis on recently registered ones, and its 2023 review of newly registered advisers listed disclosure documents and filings among the problem areas. The sequence around the filing is laid out in how to start an RIA.

Hybrids. The SEC treats unaffiliated firms as standalone broker-dealers and standalone advisers, each with its own summary. An advisor who is an investment adviser representative of an SEC-registered adviser and a registered representative of an unaffiliated broker-dealer works under two summaries, and SEC staff say retail investors generally should receive both where a delivery obligation is triggered. The structure itself is explained in what a hybrid RIA is.

What firms get wrong, and what it has cost

In July 2021 the SEC charged 27 firms, 21 advisers and 6 broker-dealers, for missing the 2020 filing, posting and delivery deadlines and acting only after two reminders, with penalties from $10,000 to $97,523. Twelve more firms followed in February 2022, $292,523 in total. In September 2024 the SEC charged five broker-dealers, $187,000 in total, four of them over the disciplinary-history disclosure: two had answered No despite reportable history, and two had not updated after a hire.

Between them, the SEC staff's 2021 statement and FINRA's exam reports list the same problems: jargon and hedging, missing headings or prescribed wording, "fiduciary" used in place of the required wording, a disciplinary answer left blank or qualified, summaries hard to find on the website, late amendments, and delivery dates nobody recorded.

The practical read for an advisor

For an advisor joining a firm, the firm's Form CRS is a short disclosure of how it is paid and where its conflicts sit. It takes about five minutes to read and is public before any meeting. For an advisor building an SEC-registered firm, it is one of the first documents written, a filing to prepare with securities counsel or a compliance professional, and it has to stay accurate as the team grows. The choice of firm or structure, and what each means for a specific practice, takes a conversation. Request an Introduction.