Considerations for Form CRS

Considerations for Form CRS

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On June 5, 2019 the SEC adopted Regulation Best Interest. The regulation created a new disclosure document: the Client Relationship Summary (Form CRS), a brief narrative which cannot exceed two pages and contains certain details about the adviser’s business, its compensation, and certain conflicts of interest.

Form CRS is required for any registered investment adviser who provides advisory service to “retail investors.” The definition of a retail investor is slightly different from FINRA rules and is far more expansive than how this term is commonly understood. A retail investor includes “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.” For clarity, this will only include clients who are natural persons or legal representatives of those persons. Investment advisers who solely advise private funds, registered funds, or have separate accounts for institutional investors will not need to complete Form CRS. It will also not include natural persons who are investors in private funds.

Wealth managers and advisers who manage separate accounts for natural persons will need to complete Form CRS, as well as make certain policy adjustments. Form CRS is required to be filed through the investment adviser registration depository (IARD) system by June 30, 2020.

Although the Form is not due till June, advisers are encouraged to reach out as soon as possible to begin the process of determining if they are in scope, what policy adjustments may need to be made, and to begin the drafting process.

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Darren Mooney

Partner and Co-Head of Business Development

Darren Mooney is a Partner and the Co-Head of Business Development at Greyline. Before joining Greyline, Darren served as deputy chief compliance officer of Partner Fund Management where he held primary responsibility for the compliance program of the second-largest hedge fund in the Bay Area. Prior to that, Darren spent five years providing compliance consulting services at Cordium and then ACA Compliance Group, where he led the company’s San Francisco office and west coast operations. In addition to providing ongoing consulting services to a variety of investment managers, including hedge fund, private equity, venture capital, real estate, quantitative and other wealth managers, Darren also regularly guided clients through the SEC registration process, implemented tailored compliance programs, supported clients’ live SEC exams, and served as an SEC-mandated independent compliance consultant following an SEC enforcement action. Darren’s other experience includes serving as deputy chief compliance officer and associate counsel at F-Squared Investments where he directly supported the compliance program during the investigation and subsequent enforcement regarding historical advertising practices. Darren has a B.S. in Economics from the University of Delaware and a J.D. from Suffolk University Law School. He is a member of the Massachusetts bar.

Annie Kong

Partner and Head of Venture Capital
Annie Kong is a Partner and Head of the Venture Capital Division at Greyline. She provides ongoing compliance consulting to investment advisers and manages client relationships. Prior to joining Greyline, Annie was part of compliance and operations at a long-only manager-of-managers that advised pension fund clients. While there, she conducted compliance and operational due diligence on SEC-registered investment advisers on the platform. She also oversaw and counseled on various legal matters across the firm. Annie has a B.A. in Economics from the University of California, San Diego, and a J.D. from the University of San Diego School of Law. She is an active member of the State Bar of California.
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