Form CRS Delivery Documentation
Please rename the BICE field under accounts to "Form CRS" so we can document Form CRS delivery under the new Regulation Best Interest (Reg BI) requirements.
The suggestion may be planned, but there is no timeline on this feature being added. This suggestion is remaining open and can continue to gather votes and comments!
Can the delivery method be added? Such as email, mail or hand delivery? It would also be helpful to have it at a client level instead of account since it doesnt need to be given per account.
Kim Baumler commented
I agree, this is frustrating. What if the form needs to be sent before we have an account number. Then what? I guess we can open a fake account, but then that is one more step when we need to make sure it matches up to the correct account later (does the information stay when you do that?) When the SEC calls and says give us the last 20 Form CRS dates that you sent out, how can we run a report that is accurate? If I have a client that rolls over retirement plans to the same account the CRS that RT has set will override the last one you did, so you don't really document all of the CRS forms that have been sent, so now I have to put it somewhere else. Also, I can look by client, but if the form was sent before we had an account number, now it is a Note and doesn't show up the report. Unless I set it up two different ways and run two different reports. If I am completely wrong about this, please show me the best way to do this. And... add to this we know have to first run a report to see what accounts were open during that time slot. Please fix this.
Joe LeBlanc commented
Unfortunately there is no way to update the BICE (now shows as CRS) field in a group since it is inside the individual account. The Know Your Client field dates can be updated as a group.
Just rename the BICE field.. don't over complicate the request and take years to implement, please!!!
Please add "Latest CRS Offering" to the Written Agreements Review Section of Know Your Client. This is a new regulatory requirement as of 2020 that we need to be able to document and report delivery dates for our clients.
Heather Hale commented
If the BICE field found under the Accounts tab would be renamed to Form CRS that would likely give us what we need.
Now that the Securities & Exchange Commission is moving forward with requiring "Form CRS Relationship Summary" reports, please generate one or more templates for this!