On February 15, 2022, the SEC announced settlements with 12 broker-dealers and investment advisers for failing to satisfy their Form CRS obligations. These settlements come on the heels of [27 settlements](/redirection.asp?article_id=1164688&company_id=477&redirectaddress=https://www.finregpolicy.com/2021/07/30/sec-charges-27-firms-with-form-crs-failures/) last year for similar violations. While all settlements included both a failure to timely file and deliver relationship summaries, in some cases the SEC also alleged that the firms failed to include information necessary to satisfy their obligations. This is consistent with prior indications that the SEC would move beyond assessing whether firms have made a good faith effort to implement Form CRS requirements and begin looking more closely...