Question

Difficulty: EasyRegulation Best Interest (Reg BI) and Form CRS Requirements

A broker-dealer updates its Form CRS (Client Relationship Summary) disclosure to reflect revised fee schedules and advisory conflicts. According to SEC recordkeeping rules under Regulation Best Interest (Reg BI), for how long must the broker-dealer retain copies of each version of its Form CRS after creation or delivery?

  1. 6 yearsAnswer
  2. B
    3 years
  3. C
    15 days after account opening
  4. D
    Until trade settlement of the customer's first transaction

Answer

Under SEC recordkeeping rules, broker-dealers must retain copies of each Form CRS (and all related customer delivery records) for 6 years.
The correct answer states 6 years. SEC Exchange Act Rule 17a-4(e)(10) requires broker-dealers to preserve copies of each Form CRS version and records of date of delivery to retail customers for at least 6 years, with the first 2 years in an easily accessible place.

Step-by-Step Solution

1
Identify the relevant regulatory rule under SEC Regulation Best Interest regarding Form CRS documentation.
Form CRS is governed by SEC Exchange Act Rule 17a-4(e)(10) alongside Reg BI compliance requirements.
Reg BI specifies strict record retention standards to ensure regulators can audit compliance with customer disclosure mandates.
2
Determine the required retention period for Form CRS records.
The rule mandates that all versions of Form CRS, amendments, and proof of delivery to retail investors must be maintained for 6 years.
Form CRS forms part of foundational customer disclosure records, placing it under the 6-year retention category rather than the standard 3-year general record category.

Key Concept

Form CRS Record Retention Schedule

Hints

1
Consider standard SEC book and record retention rules for primary customer-facing disclosure documents.
2
Form CRS is categorized alongside key customer account records rather than routine trade correspondence.
3
Major broker-dealer customer disclosure records must be retained for 6 years under SEC Exchange Act Rule 17a-4.

Practice More

Review the delivery trigger requirements for Form CRS when opening a new account for an existing retail customer.

Alternative Method

Memorize SEC Rule 17a-4 buckets: Routine trade correspondence and confirmations = 3 years; Account records, blotters, ledgers, and Form CRS = 6 years; Organizational documents (charters/articles) = Lifetime.
Estimated Time:45s
Rate this question