Investor Protection

Report on Testing of Proposed Customer Relationship Summary Disclosures

The Securities and Exchange Commission (SEC) has proposed a Customer Relationship Summary (CRS) disclosure to be provided to retail investors as they are about to begin an engagement with a Broker-Dealer or Investment Adviser. The disclosure is intended to assist investors in making an informed choice between different types of providers and different types of accounts. AARP, CFA, and the Financial Planning Coalition (FPC), including CFP Board of Standards, all filed comments with the SEC as part of the formal comment process. As a supplement to their comment letters, and in order to better analyze the SEC proposal, the groups hired Kleimann Communication Group (Kleimann) as a non-affiliated third-party to test the combined Broker-Dealer Services and Investment Adviser Services disclosure with typical consumers during July 2018. Overall, test participants had difficulty throughout the proposed CRS with sorting out the similarities and differences between the Broker-Dealer Services and Investment Adviser Services.

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