The Form ADV 3 - CRS, Client Relationship Summary or Customer Relationship Summary, depending on who you ask, is not required as of today if you are a State registered investment adviser. However, it is required for all SEC RIA firms. In my opinion, it could be a marketing advantage for State registered investment advisers to go ahead and put a Form CRS on their web site and have one available, in case a client asks for it. This is purely a business decision on your part. You have to consider the fact that you will be competiting with SEC registered investment advisers and they will have a Form CRS for their clients and prospects. I can see a scenario where these SEC RIA firms will attempt to belittle the competition, State registered investment adviser firms, and claim that "they get a loophole." You see what I mean? It could be an advantage to go ahead and prepare one, in order to compete with SEC RIA firms.
If you do want a Form CRS, then we can certainly help you with this form. The Form CRS is a two-page document and has some requirements that cannot be changed and must be included. For more information about the new Form CRS please visit the SEC web site located here. Because of the limitations of this document to two pages, it takes some critical thinking to comply with all the parts of it. This Form CRS is not a easy document to create and expert compliance help is strongly advised.