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Form CRS: A New Disclosure Obligation for Investment Advisers and Broker-Dealers

Second Quarter 2020 
By Fred Reish

This article discusses the general requirements and then dives more deeply into the application of those requirements to recommendations to 401(k) participants to roll over their accounts to IRAs with the advisor’s firm.


Fred Reish is an ERISA attorney whose practice focuses on fiduciary responsibility, retirement income, and plan operational issues. He has been recognized as one of the “legends” of the retirement industry by both PLANADVISER magazine and PLANSPONSOR magazine.


The SEC’s form CRS rule imposes new written disclosure requirements on investment advisers and broker-dealers. This article discusses the general requirements and then dives more deeply into the application of those requirements to recommendations to 401(k) participants to roll over their accounts to iras with the advisor’s firm.



The views expressed here are those of Fred Reish. They should not be construed as investment advice or as the views of Hartford Funds or the employees of Hartford Funds. They are based on available information and are subject to change without notice. The information above is intended as general information and is not intended to provide, nor may it be construed as providing, tax, accounting or legal advice. As with all matters of a tax or legal nature, please consult with your tax or legal counsel for advice. This material and/or its contents are current at the time of writing and may not be reproduced or distributed in whole or in part, for any purpose, without the express written consent of Fred Reish.

MFDC-2Q20_0420  217184