What is Form CRS?
Form CRS is a relationship summary that SEC-registered investment advisers and broker-dealers must give to retail investors. The requirement comes from Advisers Act Rule 204-5 and Exchange Act Rule 17a-14, and the SEC's instructions say the document is meant to help investors understand the services a firm offers, what they will pay, the conflicts of interest involved and the firm's legal and disciplinary history.
The SEC adopted Form CRS on June 5, 2019, in the same package as Regulation Best Interest and two interpretations under the Investment Advisers Act. Firms had to file their first relationship summaries between May 1 and June 30, 2020, begin delivering them to new and prospective retail investors by June 30, 2020, and deliver them to existing retail clients by July 30, 2020.
For investment advisers, Form CRS is Part 3 of Form ADV. This guide is general information, not legal or compliance advice; firms should rely on the current form instructions and their own counsel.
Who has to provide Form CRS?
Broker-dealers registered with the SEC under Section 15 of the Exchange Act and investment advisers registered with the SEC under Section 203 of the Advisers Act must deliver a relationship summary if they have retail investor clients or customers. A firm with no retail investors does not have to prepare or file one, according to the form instructions.
A retail investor is a natural person, or the legal representative of one, who seeks or receives services primarily for personal, family or household purposes. Institutional-only firms are outside the requirement, and state-registered advisers that are not registered with the SEC are not covered by the federal rule.
Dual registrants, firms registered as both a broker-dealer and an investment adviser that serve retail investors in both capacities, may prepare one combined summary or two separate ones. Either way, they must present brokerage and advisory information with equal prominence so investors can compare the two.
What does Form CRS have to say?
The SEC prescribes the order, headings and some of the wording. After an introduction stating the firm's name, its registration status and a pointer to the free research tools at Investor.gov/CRS, the summary must answer a series of questions: 'What investment services and advice can you provide me?'; 'What fees will I pay?'; a heading on the firm's legal obligations, how else it makes money and what conflicts it has; 'How do your financial professionals make money?'; and 'Do you or your financial professionals have legal or disciplinary history?'
Some language is mandatory. Every summary must state that the investor will pay fees and costs whether they make or lose money, and firms subject to a best-interest standard must include set wording that they have to act in the investor's best interest and not put their interest ahead of the investor's, while acknowledging that the way they make money creates conflicts. The conflicts section must cover, where they apply, proprietary products, third-party payments, revenue sharing and principal trading.
The disciplinary history answer is a plain 'Yes' or 'No.' A firm must answer yes if it or any of its financial professionals currently discloses, or is required to disclose, disciplinary information on Form ADV, Form BD, Form U4, Form U5 or Form U6, except information not released to BrokerCheck.
What are the conversation starters in Form CRS?
Each summary must include SEC-written questions for investors to ask, set off with larger type, boxes or other formatting so they stand out. They include 'How will you choose investments to recommend to me?', 'What is your relevant experience, including your licenses, education and other qualifications?', 'How might your conflicts of interest affect me, and how will you address them?' and 'As a financial professional, do you have any disciplinary history? For what type of conduct?'
The fee question is the most concrete: 'Help me understand how these fees and costs might affect my investments. If I give you $10,000 to invest, how much will go to fees and costs, and how much will be invested for me?' Firms that offer only automated or online services must answer the conversation starters on a dedicated web page.
How long can Form CRS be, and how is it delivered?
A relationship summary may not exceed two pages in paper format, or four pages for a dual registrant that covers both brokerage and advisory services in one document. Electronic versions must stay within the equivalent length and may use hyperlinks, pop-ups and other tools to point to more detail. The SEC requires plain English, written as if speaking directly to the investor.
Timing depends on the business. An investment adviser must deliver the summary before or at the time it enters an advisory contract, even an oral one. A broker-dealer must deliver it before or at the earliest of recommending an account type, securities transaction or strategy; placing an order; or opening an account. Firms must also deliver the latest version to existing clients before opening a new type of account, recommending a rollover from a retirement account or recommending a new service or investment outside an existing account, and within 30 days of a client's request.
If delivered on paper as part of a package, the relationship summary has to be first in the stack. Firms with a public website must post the current version prominently.
How often does Form CRS have to be updated?
Firms must update and refile the summary within 30 days whenever any information in it becomes materially inaccurate. The amended filing must include an exhibit highlighting the changes, such as marked text or a summary of material changes.
Existing retail clients must be told about the changes within 60 days after the update is required, at no charge, either by delivering the amended summary or by communicating the information through another disclosure.
How has the SEC enforced Form CRS?
The first enforcement actions targeted firms that never filed or delivered the form. On July 26, 2021, the SEC announced settled charges against 21 investment advisers and six broker-dealers that failed to file and deliver relationship summaries on time; the firms agreed to be censured and to pay penalties ranging from $10,000 to $97,523, and none had acted until reminded twice by SEC examiners or FINRA. On Feb. 15, 2022, the SEC charged 12 more firms, six advisers and six broker-dealers, bringing the total charged for Form CRS failures to 42.
SEC staff have also flagged quality problems. A Dec. 17, 2021 statement from the SEC's Standards of Conduct Implementation Committee said some summaries used jargon, added disclaimers the form does not permit, left out required headings or conversation starters, used marketing language, or were hard to find on firms' websites.
The issue remains on examiners' list. In its fiscal 2026 examination priorities, released Nov. 17, 2025, the SEC's Division of Examinations said it would review broker-dealers' relationship summaries, including how they describe their services, fees and costs, conflicts of interest, and disciplinary history.
Where can investors find a firm's Form CRS?
Firms with websites must post their current relationship summary prominently. Relationship summaries filed by investment advisers are also posted with their records on the SEC's Investment Adviser Public Disclosure site, and every summary must direct investors to Investor.gov/CRS, the SEC's free tool for researching firms and financial professionals.
Form CRS is a starting point, not the full disclosure. Each section must point to more detailed information, such as an adviser's Form ADV Part 2A brochure or a broker-dealer's Regulation Best Interest disclosures. Our guides to Form ADV and to checking a financial advisor explain how to use those records.