Published Articles
March-April, 2020
New Obligation to the SEC: Client relationship summaries will be needed to do rollovers
Los Angeles partner Fred Reish and Florham Park counsel Joan Neri explain how the new SEC Client Relationship Summary (CRS) disclosure obligation applies to rollovers in the March–April 2020 edition of planadviser.com. When an adviser recommends a rollover, this new disclosure obligation will apply along with the best interest standard of conduct. Fred and Joan explain how the Form CRS disclosure applies to new and existing clients and the time frame and delivery methods for each. The authors emphasize that “advisers should evaluate how they practice giving rollover advice and integrate Form CRS delivery into their processes.”