UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

FORM CRS

Sections 3, 10, 15, 15(c)(6), 15(l), 17, 23, and 36 of the Securities Exchange Act of 1934 (“Exchange Act”) and 

section 913(f) of Title IX of the Dodd-Frank Act authorize the Commission to require the collection of the 

information on Form CRS from brokers and dealers. See 15 U.S.C. 78c, 78j, 78o, 78o(c)(6), 78o(l), 78q, 78w and 

78mm. Filing Form CRS is mandatory for every broker or dealer registered with the Commission pursuant to 

section 15 of the Exchange Act that offers services to a retail investor. See 17 CFR 240.17a-14. Intentional 

misstatements or omissions constitute federal criminal violations (see 18 U.S.C. § 1001 and 15 U.S.C. 78ff(a)). The 

Commission may use the information provided in Form CRS to manage its regulatory and examination programs. 

Form CRS is made publically available. 

An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless 

it displays a currently valid control number. Any member of the public may direct to the Commission any

comments concerning the accuracy of this burden estimate and any suggestions for reducing this burden. This 

collection of information has been reviewed by the Office of Management and Budget in accordance with the 

requirements of 44 U.S.C. § 3507. 

The information contained in the form is part of a system of records subject to the Privacy Act of 1974, as amended. 

The information may be disclosed as outlined above and in the routine uses listed in the applicable system of records 

notice, SEC-70, SEC’s Division of Trading and Markets Records, published in the Federal Register at 83 FR 6892 

(February 15, 2018).

SEC 2942 (05-20)

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hours per response: 0.019
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General Instructions

Under rule 17a-14 under the Securities Exchange Act of 1934 and rule 204-5 under the 

Investment Advisers Act of 1940, broker-dealers registered under section 15 of the Exchange 

Act and investment advisers registered under section 203 of the Advisers Act are required to 

deliver to retail investors a relationship summary disclosing certain information about the firm.

1

Read all the General Instructions as well as the particular item requirements before preparing or 

updating the relationship summary.

If you do not have any retail investors to whom you must deliver a relationship summary, you 

are not required to prepare or file one. See also Advisers Act rule 204-5; Exchange Act rule 17a14(a).

1. Format. 

A. The relationship summary must include the required items enumerated below. 

The items require you to provide specific information.

B. You must respond to each item and must provide responses in the same order as 

the items appear in these instructions. You may not include disclosure in the 

relationship summary other than disclosure that is required or permitted by these 

Instructions and the applicable item. 

C. You must make a copy of the relationship summary available upon request

without charge. In paper format, the relationship summary for broker-dealers and 

investment advisers must not exceed two pages. For dual registrants that include 

their brokerage services and investment advisory services in one relationship 

summary, it must not exceed four pages in paper format. Dual registrants and 

affiliates that prepare separate relationship summaries are limited to two pages for 

each relationship summary. See General Instruction 5. You must use reasonable 

paper size, font size, and margins. If delivered electronically, the relationship 

summary must not exceed the equivalent of two pages or four pages in paper 

format, as applicable.

2. Plain English; Fair Disclosure. 

A. The items of the relationship summary are designed to promote effective 

communication between you and retail investors. Write your relationship 

summary in plain English, taking into consideration retail investors’ level of 

financial experience. You should include white space and implement other design 

features to make the relationship summary easy to read. The relationship 

summary should be concise and direct. Specifically: (i) use short sentences and 

paragraphs; (ii) use definite, concrete, everyday words; (iii) use active voice; (iv) 

 1 Terms that are italicized in these instructions are defined in General Instruction 11.
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avoid legal jargon or highly technical business terms unless you clearly explain 

them; and (v) avoid multiple negatives. You must write your response to each 

item as if you are speaking to the retail investor, using “you,” “us,” “our firm,” 

etc.

Note: The SEC’s Office of Investor Education and Advocacy has published A 

Plain English Handbook. You may find the handbook helpful in writing your 

relationship summary. For a copy of this handbook, visit the SEC’s website at 

www.sec.gov/news/extra/handbook.htm.

B. All information in your relationship summary must be true and may not omit any 

material facts necessary in order to make the disclosures required by these 

Instructions and the applicable Item, in light of the circumstances under which 

they were made, not misleading. If a required disclosure or conversation starter is 

inapplicable to your business or specific wording required by these Instructions is 

inaccurate, you may omit or modify that disclosure or conversation starter.

C. Responses must be factual and provide balanced descriptions to help retail 

investors evaluate your services. For example, you may not include exaggerated 

or unsubstantiated claims, vague and imprecise “boilerplate” explanations, or 

disproportionate emphasis on possible investments or activities that are not 

offered to retail investors. 

D. Broker-dealers and investment advisers have disclosure and reporting obligations 

under state and federal laws, including, but not limited to, obligations under the 

Exchange Act, the Advisers Act, and the respective rules thereunder. Brokerdealers are also subject to disclosure obligations under the rules of self-regulatory 

organizations. Delivery of the relationship summary will not necessarily satisfy 

the additional requirements that you have under the federal securities laws and 

regulations or other laws or regulations.

3. Electronic and Graphical Formats.

A. You are encouraged to use charts, graphs, tables, and other graphics or text 

features in order to respond to the required disclosures. You are also encouraged 

to use text features, text colors, and graphical cues, such as dual-column charts, to 

compare services, account characteristics, investments, fees, and conflicts of 

interest. For a relationship summary that is posted on your website or otherwise 

provided electronically, we encourage online tools that populate information in 

comparison boxes based on investor selections. You also may include: (i) a 

means of facilitating access to video or audio messages, or other forms of 

information (whether by hyperlink, website address, Quick Response Code (“QR 

code”), or other equivalent methods or technologies); (ii) mouse-over windows;

(iii) pop-up boxes; (iv) chat functionality; (v) fee calculators; or (vi) other forms 
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of electronic media, communications, or tools designed to enhance a retail

investor’s understanding of the material in the relationship summary. 

B. In a relationship summary that is posted on your website or otherwise provided 

electronically, you must provide a means of facilitating access to any information 

that is referenced in the relationship summary if the information is available 

online, including, for example, hyperlinks to fee schedules, conflicts disclosures, 

the firm’s narrative brochure required by Part 2A of Form ADV, or other 

regulatory disclosures. In a relationship summary that is delivered in paper

format, you may include URL addresses, QR codes, or other means of facilitating

access to such information.

C. Explanatory or supplemental information included in the relationship summary

pursuant to General Instructions 3.A. or 3.B.: (i) must be responsive to and meet 

the requirements in these instructions for the particular Item in which the 

information is placed; and (ii) may not, because of the nature, quantity, or manner 

of presentation, obscure or impede understanding of the information that must be 

included. When using interactive graphics or tools, you may include instructions 

on their use and interpretation.

4. Formatting for Conversation Starters, Additional Information, and Standard of 

Conduct.

A. For the “conversation starters” required by Items 2, 3, 4, and 5 below, you must 

use text features to make the conversation starters more noticeable and prominent

in relation to other discussion text, for example, by: using larger or different font,

a text box around the heading or questions; bolded, italicized or underlined text;

or lines to offset the questions from the other sections. 

B. Investment advisers that provide only automated investment advisory services or 

broker-dealers that provide services only online without a particular individual 

with whom a retail investor can discuss these conversation starters must include a 

section or page on their website that answers each of the questions and must

provide in the relationship summary a means of facilitating access to that section 

or page. If you provide automated investment advisory or brokerage services but 

also make a financial professional available to discuss your services with a retail 

investor, a financial professional must be available to discuss these conversation 

starters with the retail investor.

C. For references to additional information regarding services, fees, and conflicts of 

interest required by Items 2.C., 3.A.(iii), and 3.B.(iv) below, you must use text 

features to make this information more noticeable and prominent in relation to 

other discussion text, for example, by: using larger or different font, a text box 

around the heading or questions, bolded, italicized or underlined text, or lines to 

offset the information from the other sections. A relationship summary provided 
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electronically must include a hyperlink, QR code, or other means of facilitating 

access that leads directly to the relevant additional information. 

5. Dual Registrants, Affiliates, and Additional Services.

A. If you are a dual registrant, you are encouraged to prepare a single relationship 

summary discussing both your brokerage and investment advisory services.

Alternatively, you may prepare two separate relationship summaries for 

brokerage services and investment advisory services. Whether you prepare a 

single relationship summary or two, you must present the brokerage and 

investment advisory information with equal prominence and in a manner that 

clearly distinguishes and facilitates comparison of the two types of services. If 

you prepare two separate relationship summaries, you must reference and provide 

a means of facilitating access to the other, and you must deliver to each retail 

investor both relationship summaries with equal prominence and at the same 

time, without regard to whether the particular retail investor qualifies for those 

retail services or accounts. 

B. If you are a broker-dealer or investment adviser and your affiliate also provides 

brokerage or investment advisory services to retail investors, you may prepare a 

single relationship summary discussing the services you and your affiliate

provide. Alternatively, you may prepare separate relationship summaries for your 

services and your affiliate’s services. 

(i) Whether you prepare a single relationship summary or separate 

relationship summaries, you must design them in a manner that presents 

the brokerage and investment advisory information with equal prominence 

and clearly distinguishes and facilitates comparison of the two types of

services. 

(ii) If you prepare separate relationship summaries:

a. If a dually licensed financial professional provides brokerage and 

investment advisory services on behalf of you and your affiliate,

you must deliver to each retail investor both your and your 

affiliate’s relationship summaries with equal prominence and at

the same time, without regard to whether the particular retail 

investor qualifies for those retail services or accounts. Each of the 

relationship summaries must reference and provide a means of

facilitating access to the other.

b. If General Instruction 5.B.(ii)(a) does not apply, you may choose 

whether or not to reference and provide a means of facilitating 

access to your affiliate’s relationship summary and whether or not

to deliver your and your affiliate’s relationship summaries to each 

retail investor with equal prominence and at the same time.
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C. You may acknowledge other financial services that you provide in addition to 

your services as a broker-dealer or investment adviser registered with the SEC, 

such as insurance, banking, or retirement services, or investment advice pursuant 

to state registration or licensing. You may include references and means of 

facilitating access to additional information about those services. Information not 

pertaining to brokerage or investment advisory services may not, because of the 

nature, quantity, or manner of presentation, obscure or impede understanding of 

the information that must be included. See also General Instruction 3.C.

6. Preserving Records.

A. You must maintain records in accordance with Advisers Act rule 204-2(a)(14)(i)

and/or Exchange Act rule 17a-4(e)(10), as applicable. 

7. Initial Filing and Delivery; Transition Provisions. 

A. Initial filing. 

(i) If you are an investment adviser and are required to deliver a relationship 

summary to a retail investor, you must file Form ADV, Part 3 (Form CRS) 

electronically with the Investment Adviser Registration Depository 

(IARD). If you are a registered broker-dealer and are required to deliver a 

relationship summary to a retail investor, you must file Form CRS

electronically through the Central Registration Depository (“Web

CRD®”) operated by the Financial Industry Regulatory Authority, Inc. 

(FINRA). If you are a dual registrant and are required to deliver a 

relationship summary to one or more retail investor clients or customers 

of both your investment advisory and brokerage businesses, you must file 

using IARD and Web CRD®. You must file Form CRS using a textsearchable format with machine-readable headings.

(ii) Information for investment advisers on how to file with IARD is available 

on the SEC’s website at www.sec.gov/iard. Information for brokerdealers on how to file through Web CRD® is available on FINRA’s

website at http://www.finra.org/industry/web-crd/web-crd-system-links.

B. Initial delivery. 

(i) Investment Advisers: If you are an investment adviser, you must deliver a 

relationship summary to each retail investor before or at the time you 

enter into an investment advisory contract with the retail investor. You 

must deliver the relationship summary even if your agreement with the 

retail investor is oral. See Advisers Act rule 204-5(b)(1).

(ii) Broker-Dealers: If you are a broker-dealer, you must deliver a 

relationship summary to each retail investor, before or at the earliest of: 
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(i) a recommendation of an account type, a securities transaction, or an 

investment strategy involving securities; (ii) placing an order for the retail 

investor; or (iii) the opening of a brokerage account for the retail investor. 

See Exchange Act rule 17a-14(c)(1). 

(iii) Dual Registrants: A dual registrant must deliver the relationship 

summary at the earlier of the timing requirements in General Instruction 

7.B.(i) or (ii).

C. Transition provisions for initial filing and delivery after the effective date of 

the new Form CRS requirements. 

(i) Filings for Investment Advisers 

a. If you are already registered or have an application for registration 

pending with the SEC as an investment adviser before June 30, 

2020 you must electronically file, in accordance with Instruction 

7.A. above, your initial relationship summary beginning on May 1, 

2020 and by no later than June 30, 2020 either as: (1) an otherthan-annual amendment or (2) part of your initial application or 

annual updating amendment. See Advisers Act rules 203-1 and

204-1. 

b. If you file an application for registration with the SEC as an 

investment adviser on or after June 30, 2020, the Commission will 

not accept any initial application that does not include a

relationship summary. See Advisers Act rule 203-1.

(ii) Filings for Broker-Dealers

a. If you are already registered with the SEC as a broker-dealer

before June 30, 2020, you must electronically file, in accordance 

with Instruction 7.A. above, your initial relationship summary

beginning on May 1, 2020 and by no later than June 30, 2020. See 

Exchange Act rule 17a-14. 

b. If you file an application for registration or have an application 

pending with the SEC as a broker-dealer on or after June 30, 2020, 

you must file your relationship summary by no later than the date 

that your registration becomes effective. See Exchange Act rule 

17a-14.

(iii) Delivery to New and Prospective Clients and Customers: As of the date by 

which you are first required to electronically file your relationship 

summary with the SEC, you must begin to deliver your relationship 

summary to new and prospective clients and customers who are retail 
8

investors as required by Instruction 7.B. See Advisers Act rule 204-5 and 

Exchange Act rule 17a-14.

(iv) Delivery to Existing Clients and Customers: Within 30 days after the date 

by which you are first required to electronically file your relationship 

summary with the SEC, you must deliver your relationship summary to 

each of your existing clients and customers who are retail investors. See 

Advisers Act rule 204-5 and Exchange Act rule 17a-14.

8. Updating the Relationship Summary and Filing Amendments.

A. You must update your relationship summary and file it in accordance with 

Instruction 7.A. above within 30 days whenever any information in the 

relationship summary becomes materially inaccurate. The filing must include an 

exhibit highlighting changes required by Instruction 8.C. below. 

B. You must communicate any changes in the updated relationship summary to 

retail investors who are existing clients or customers within 60 days after the 

updates are required to be made and without charge. You can make the 

communication by delivering the amended relationship summary or by

communicating the information through another disclosure that is delivered to the 

retail investor. 

C. Each amended relationship summary that is delivered to a retail investor who is 

an existing client or customer must highlight the most recent changes by, for 

example, marking the revised text or including a summary of material changes. 

The additional disclosure showing revised text or summarizing the material 

changes must be attached as an exhibit to the unmarked amended relationship 

summary.

9. Additional Delivery Requirements to Existing Clients and Customers. 

A. You must deliver the most recent relationship summary to a retail investor who is 

an existing client or customer before or at the time you: (i) open a new account

that is different from the retail investor’s existing account(s); (ii) recommend that 

the retail investor roll over assets from a retirement account into a new or existing 

account or investment; or (iii) recommend or provide a new brokerage or 

investment advisory service or investment that does not necessarily involve the 

opening of a new account and would not be held in an existing account, for 

example, the first-time purchase of a direct-sold mutual fund or insurance product 

that is a security through a “check and application” process, i.e., not held directly 

within an account.

B. You also must deliver the relationship summary to a retail investor within 30 

days upon the retail investor’s request. 
9

10. Electronic Posting and Manner of Delivery. 

A. You must post the current version of the relationship summary prominently on 

your public website, if you have one, in a location and format that is easily 

accessible for retail investors. 

B. You may deliver the relationship summary electronically, including updates, 

consistent with SEC guidance regarding electronic delivery, in particular Use of 

Electronic Media by Broker-Dealers, Transfer Agents, and Investment Advisers 

for Delivery of Information, which you can find at 

www.sec.gov/rules/concept/33-7288.txt. You may deliver the relationship 

summary to new or prospective clients or customers in a manner that is consistent 

with how the retail investor requested information about you or your financial 

professional consistent with SEC guidance, in particular Form CRS Relationship 

Summary; Amendments to Form ADV, which you can find at [INSERT LINK].

C. If the relationship summary is delivered electronically, it must be presented 

prominently in the electronic medium, for example, as a direct link or in the body 

of an email or message, and must be easily accessible for retail investors.

D. If the relationship summary is delivered in paper format as part of a package of

documents, you must ensure that the relationship summary is the first among any 

documents that are delivered at that time.

11. Definitions.

For purposes of Form CRS and these Instructions, the following terms have the meanings 

ascribed to them below: 

A. Affiliate: Any persons directly or indirectly controlling or controlled by you or 

under common control with you. 

B. Dually licensed financial professional: A natural person who is both an 

associated person of a broker-dealer registered under section 15 of the Exchange 

Act, as defined in section 3(a)(18) of the Exchange Act, and a supervised person 

of an investment adviser registered under section 203 of the Advisers Act, as 

defined in section 202(a)(25) of the Advisers Act.

C. Dual registrant: A firm that is dually registered as a broker-dealer under section 

15 of the Exchange Act and an investment adviser under section 203 of the 

Advisers Act and offers services to retail investors as both a broker-dealer and an 

investment adviser. For example, if you are dually registered and offer 

investment advisory services to retail investors, but offer brokerage services only 

to institutional investors, you are not a dual registrant for purposes of Form CRS 

and these Instructions.
10

D. Relationship summary: A written disclosure statement prepared in accordance 

with these Instructions that you must provide to retail investors. See Advisers 

Act rule 204-5; Exchange Act rule 17a-14; Form CRS.

E. Retail investor: A natural person, or the legal representative of such natural 

person, who seeks to receive or receives services primarily for personal, family or 

household purposes.
11

Item Instructions

Item 1. Introduction

Include the date prominently at the beginning of the relationship summary (e.g., in the header or 

footer of the first page or in a similar location for a relationship summary provided 

electronically). Briefly discuss the following information in an introduction:

A. State your name and whether you are registered with the Securities and Exchange 

Commission as a broker-dealer, investment adviser, or both. Also indicate that 

brokerage and investment advisory services and fees differ and that it is important 

for the retail investor to understand the differences. You may also include a 

reference to FINRA or Securities Investor Protection Corporation membership in 

a manner consistent with other rules or regulations (e.g., FINRA rule 2210).

B. State that free and simple tools are available to research firms and financial 

professionals at Investor.gov/CRS, which also provides educational materials 

about broker-dealers, investment advisers, and investing. 

Item 2. Relationships and Services

A. Use the heading: “What investment services and advice can you provide me?” 

B. Description of Services: State that you offer brokerage services, investment 

advisory services, or both, to retail investors, and summarize the principal 

services, accounts, or investments you make available to retail investors, and any 

material limitations on such services. For broker-dealers, state the particular 

types of principal brokerage services you offer to retail investors, including

buying and selling securities, and whether or not you offer recommendations to 

retail investors. For investment advisers, state the particular types of principal 

investment advisory services you offer to retail investors, including, for example, 

financial planning and wrap fee programs.

In your description you must address the following:

(i) Monitoring: Explain whether or not you monitor retail investors’

investments, including the frequency and any material limitations. If so, 

indicate whether or not the services described in response to this Item 

2.B.(i) are offered as part of your standard services.

(ii) Investment Authority: For investment advisers that accept discretionary 

authority, describe those services and any material limitations on that

authority. Any such summary must include the specific circumstances 

that would trigger this authority and any material limitations on that 

authority (e.g., length of time). For investment advisers that offer non-
12

discretionary services and broker-dealers, explain that the retail investor 

makes the ultimate decision regarding the purchase or sale of investments. 

Broker-dealers may, but are not required to state whether you accept 

limited discretionary authority. 

Note: If you are a broker-dealer offering recommendations, you should consider 

the applicability of the Investment Advisers Act of 1940, consistent with SEC 

guidance.

(iii) Limited Investment Offerings: Explain whether or not you make available 

or offer advice only with respect to proprietary products, or a limited 

menu of products or types of investments, and if so, describe these 

limitations.

(iv) Account Minimums and Other Requirements: Explain whether or not you 

have any requirements for retail investors to open or maintain an account

or establish a relationship, such as minimum account size or investment

amount. 

C. Additional Information: Include specific references to more detailed 

information about your services that, at a minimum, include the same or 

equivalent information to that required by the Form ADV, Part 2A brochure 

(Items 4 and 7 of Part 2A or Items 4.A. and 5 of Part 2A Appendix 1) and 

Regulation Best Interest, as applicable. If you are a broker-dealer that does not 

provide recommendations subject to Regulation Best Interest, to the extent you 

prepare more detailed information about your services, you must include specific 

references to such information. You may include hyperlinks, mouse-over 

windows, or other means of facilitating access to this additional information and 

to any additional examples or explanations of such services.

D. Conversation Starters: Include the following additional questions for a retail 

investor to ask a financial professional and start a conversation about relationships 

and services:

(i) If you are a broker-dealer and not a dual registrant, include: “Given my 

financial situation, should I choose a brokerage service? Why or why 

not?”

(ii) If you are an investment adviser and not a dual registrant, include: “Given 

my financial situation, should I choose an investment advisory service? 

Why or why not?”

(iii) If you are a dual registrant, include: “Given my financial situation, should 

I choose an investment advisory service? Should I choose a brokerage 

service? Should I choose both types of services? Why or why not?” 

(iv) “How will you choose investments to recommend to me?”
13

(v) “What is your relevant experience, including your licenses, education and 

other qualifications? What do these qualifications mean?”

Item 3. Fees, Costs, Conflicts, and Standard of Conduct 

A. Use the heading: “What fees will I pay?”

(i) Description of Principal Fees and Costs: Summarize the principal fees 

and costs that retail investors will incur for your brokerage or investment 

advisory services, including how frequently they are assessed and the 

conflicts of interest they create. 

a. Broker-dealers must describe their transaction-based fees. With 

respect to addressing conflicts of interest, a broker-dealer could, 

for example, include a statement that a retail investor would be 

charged more when there are more trades in his or her account, and 

that the firm may therefore have an incentive to encourage a retail 

investor to trade often.

b. Investment advisers must describe their ongoing asset-based fees, 

fixed fees, wrap fee program fees, or other direct fee arrangement.

The principal fees for investment advisory services should align 

with the type of fee(s) that you report in response to Form ADV 

Part 1A, Item 5.E. 

(1) Include information about each type of fee you report in Form 

ADV that is responsive to this Item 3.A. Investment advisers 

with wrap fee program fees are encouraged to explain that 

asset-based fees associated with the wrap fee program will 

include most transaction costs and fees to a broker-dealer or 

bank that has custody of these assets, and therefore are higher 

than a typical asset-based advisory fee. 

(2) With respect to addressing conflicts of interest, an investment 

adviser that charges an asset-based fee could, for example,

include a statement that the more assets there are in a retail 

investor’s advisory account, the more a retail investor will pay 

in fees, and the firm may therefore have an incentive to 

encourage the retail investor to increase the assets in his or her 

account.

Note: If you receive compensation in connection with the purchase 

or sale of securities, you should carefully consider the applicability 

of the broker-dealer registration requirements of the Securities 

Exchange Act of 1934 and any applicable state securities statutes.
14

(ii) Description of Other Fees and Costs: Describe other fees and costs 

related to your brokerage or investment advisory services and investments 

in addition to the firm’s principal fees and costs disclosed in Item 3.A.(i) 

that the retail investor will pay directly or indirectly. List examples of the 

categories of the most common fees and costs applicable to your retail 

investors (e.g., custodian fees, account maintenance fees, fees related to 

mutual funds and variable annuities, and other transactional fees and 

product-level fees). 

(iii) Additional Information: State “You will pay fees and costs whether you 

make or lose money on your investments. Fees and costs will reduce any

amount of money you make on your investments over time. Please make 

sure you understand what fees and costs you are paying.” You must 

include specific references to more detailed information about your fees 

and costs that, at a minimum, include the same or equivalent information 

to that required by the Form ADV, Part 2A brochure (specifically Items 

5.A., B., C., and D.) and Regulation Best Interest, as applicable. If you are 

a broker-dealer that does not provide recommendations subject to 

Regulation Best Interest, to the extent you prepare more detailed 

information about your fees and costs, you must include specific 

references to such information. You may include hyperlinks, mouse-over 

windows, or other means of facilitating access to this additional 

information and to any additional examples or explanations of such fees

and costs included in response to Item 3.A.(i) or (ii).

(iv) Conversation Starter: Include the following question for a retail investor 

to ask a financial professional and start a conversation about the impact of 

fees and costs on investments: “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?”

B. If you are a broker-dealer, use the heading: “What are your legal obligations to 

me when providing recommendations? How else does your firm make money 

and what conflicts of interest do you have?” If you are an investment adviser, use

the heading: “What are your legal obligations to me when acting as my 

investment adviser? How else does your firm make money and what conflicts of 

interest do you have?” If you are a dual registrant that prepares a single

relationship summary, use the heading: “What are your legal obligations to me 

when providing recommendations as my broker-dealer or when acting as my 

investment adviser? How else does your firm make money and what conflicts of 

interest do you have?”

(i) Standard of Conduct.

a. If you are a broker-dealer that provides recommendations subject 

to Regulation Best Interest, include (emphasis required): “When 
15

we provide you with a recommendation, we have to act in your 

best interest and not put our interest ahead of yours. At the same 

time, the way we make money creates some conflicts with your 

interests. You should understand and ask us about these conflicts 

because they can affect the recommendations we provide you. 

Here are some examples to help you understand what this means.” 

If you are a broker-dealer that does not provide recommendations

subject to Regulation Best Interest, include (emphasis 

required): “We do not provide recommendations. The way we 

make money creates some conflicts with your interests. You 

should understand and ask us about these conflicts because they 

can affect the services we provide you. Here are some examples to 

help you understand what this means.”

b. If you are an investment adviser, include (emphasis required): 

“When we act as your investment adviser, we have to act in your 

best interest and not put our interest ahead of yours. At the same 

time, the way we make money creates some conflicts with your 

interests. You should understand and ask us about these conflicts 

because they can affect the investment advice we provide you. 

Here are some examples to help you understand what this means.”

c. If you are a dual registrant that prepares a single relationship 

summary and you provide recommendations subject to Regulation 

Best Interest as a broker-dealer, include (emphasis required): 

“When we provide you with a recommendation as your brokerdealer or act as your investment adviser, we have to act in your 

best interest and not put our interest ahead of yours. At the same 

time, the way we make money creates some conflicts with your 

interests. You should understand and ask us about these conflicts 

because they can affect the recommendations and investment 

advice we provide you. Here are some examples to help you 

understand what this means.” If you are a dual registrant that 

prepares a single relationship summary and you do not provide 

recommendations subject to Regulation Best Interest as a brokerdealer, include (emphasis required): “We do not provide 

recommendations as your broker-dealer. When we act as your

investment adviser, we have to act in your best interest and not put 

our interests ahead of yours. At the same time, the way we make 

money creates some conflicts with your interest. You should

understand and ask us about these conflicts because they can affect 

the services and investment advice we provide you. Here are some 

examples to help you understand what this means.” If you are a 

dual registrant that prepares two separate relationship summaries, 
16

follow the instructions for broker-dealers and investment advisers 

in Items 3.B., 3.B.(i).a., and 3.B.(i).b.

(ii) Examples of Ways You Make Money and Conflicts of Interest: If 

applicable to you, summarize the following other ways in which you and 

your affiliates make money from brokerage or investment advisory 

services and investments you provide to retail investors. If none of these 

conflicts applies to you, summarize at least one other material conflict of 

interest that affects retail investors. Explain the incentives created by each 

of these examples.

a. Proprietary Products: Investments that are issued, sponsored, or 

managed by you or your affiliates.

b. Third-Party Payments: Compensation you receive from third 

parties when you recommend or sell certain investments. 

c. Revenue Sharing: Investments where the manager or sponsor of 

those investments or another third party (such as an intermediary) 

shares with you revenue it earns on those investments. 

d. Principal Trading: Investments you buy from a retail investor, 

and/or investments you sell to a retail investor, for or from your 

own accounts, respectively. 

(iii) Conversation Starter: Include the following question for a retail investor 

to ask a financial professional and start a conversation about conflicts of 

interest: “How might your conflicts of interest affect me, and how will you 

address them?”

(iv) Additional Information: You must include specific references to more 

detailed information about your conflicts of interest that, at a minimum, 

include the same or equivalent information to that required by the Form 

ADV, Part 2A brochure and Regulation Best Interest, as applicable. If 

you are a broker-dealer that does not provide recommendations subject to 

Regulation Best Interest, to the extent you prepare more detailed 

information about your conflicts, you must include specific references to 

such information. You may include hyperlinks, mouse-over windows, or 

other means of facilitating access to this additional information and to any 

additional examples or explanations of such conflicts of interest.

C. Use the heading: “How do your financial professionals make money?”

(i) Description of How Financial Professionals Make Money: Summarize

how your financial professionals are compensated, including cash and 

non-cash compensation, and the conflicts of interest those payments 

create. 
17

(ii) Required Topics in the Description: Include, to the extent applicable, 

whether your financial professionals are compensated based on factors 

such as: the amount of client assets they service; the time and complexity 

required to meet a client’s needs; the product sold (i.e., differential 

compensation); product sales commissions; or revenue the firm earns from 

the financial professional’s advisory services or recommendations. 

Item 4. Disciplinary History

A. Use the heading: “Do you or your financial professionals have legal or 

disciplinary history?”

B. State “Yes” if you or any of your financial professionals currently disclose, or are 

required to disclose, the following information:

(i) Disciplinary information in your Form ADV (Item 11 of Part 1A or Item 9 

of Part 2A).

(ii) Legal or disciplinary history in your Form BD (Items 11 A–K) (except to 

the extent such information is not released to BrokerCheck, pursuant to 

FINRA Rule 8312). 

(iii) Disclosures for any of your financial professionals in Items 14 A–M on 

Form U4 (Uniform Application for Securities Industry Registration or 

Transfer), or in Items 7A or 7C–F of Form U5 (Uniform Termination 

Notice for Securities Industry Registration), or on Form U6 (Uniform 

Disciplinary Action Reporting Form) (except to the extent such 

information is not released to BrokerCheck, pursuant to FINRA Rule 

8312).

C. State “No” if neither you nor any of your financial professionals currently 

discloses, or is required to disclose, the information listed in Item 4.B.

D. Regardless of your response to Item 4.B, you must:

(i) Search Tool: Direct the retail investor to visit Investor.gov/CRS for a free 

and simple search tool to research you and your financial professionals. 

(ii) Conversation Starter: Include the following questions for a retail investor 

to ask a financial professional and start a conversation about the financial 

professional’s disciplinary history: “As a financial professional, do you 

have any disciplinary history? For what type of conduct?”

Item 5. Additional Information

A. State where the retail investor can find additional information about your 

brokerage or investment advisory services and request a copy of the relationship 
18

summary. This information should be disclosed prominently at the end of the 

relationship summary.

B. Include a telephone number where retail investors can request up-to-date 

information and request a copy of the relationship summary.

C. Conversation Starter: Include the following questions for a retail investor to 

ask a financial professional and start a conversation about the contacts and 

complaints: “Who is my primary contact person? Is he or she a representative of 

an investment adviser or a broker-dealer? Who can I talk to if I have concerns 

about how this person is treating me?”