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? |