After all the hype and noise about Form CRS, which was first required to be issued this summer, it appears that the intended audience – investment clients – are generally uninterested in the new disclosures and not engaged in the process of asking questions of their advisers. Research shows that almost no-one who received the new form, among the tens of thousands of clients who did, raised any issue or question with their advisor regarding Form CRS and its use.

Not surprisingly, this logically fits in with the response of clients to required disclosures generally: adding a few new pages with a somewhat different approach to the pile does not engender interest in persons already overwhelmed with information and fine print (much of it irrelevant and/or confusing). It probably provided employment to the rule drafters at the SEC and to a variety of attorneys and compliance persons who were well paid to help firms generate the documents newly required. The actual benefit to those most directly impacted – clients and their advisors – not so much.

Whether you are an advisor or investor, it would be interesting (and helpful) if you would share your thoughts and experiences on this latest venture of the regulators to ostensibly help investors. As an investor, have you asked your advisor(s) any questions based on what Form CRS addresses and suggests you ask? If you are an advisor, have your clients acknowledged and made use of the disclosures in any meaningful way?