How Massachusetts’ Proposed One-Page Fee Table Trumps SEC’s Form CRS
Fiduciary advocates have expressed support for a proposal from Massachusetts’ top securities cop to require investment advisors to put out a simplified document outlining their fees regardless of how they’re charged, contrasting it with what they see as the SEC’s problematic proposal to offer investors a Client Relationship Summary (Form CRS), according to news reports.
Last month, the Office of the Secretary of the Commonwealth proposed requiring investment advisors to offer clients a one-page fee table in a bid to help advice clients shop around for services in a clearer way. The table would essentially summarize information already available on Form ADV Part 2A, but Secretary of State William Galvin’s office said at the time that it would make it easier for clients to note the differences between various ways advisors charge fees, from subscriptions and retainers to asset-based fees and third-party advice fees.
Last week, a day before the May 3 scheduled close of the comment period on the proposal, the Institute for the Fiduciary Standard told the Massachusetts Securities Divisions that the proposal “is an important step towards a complete reporting on all-in cost and fees and expenses as is now required in the EU,” according to FA magazine. Furthermore, Knut Rostad, the institute’s president, said in a separate comment letter that the proposal would help clients “engage in intelligent conversations with an investment professional and can better comprehend a firm’s value proposition and they can become better educated consumers,” the publication writes.
By contrast, Rostad pointed to the response from investors to the SEC’s Form CRS, according to FA magazine. Around 41% of investors said they were dissatisfied with the rule at the commission’s largest roundtable on its proposed overhaul of broker and investment adviser conduct rules, which took place in Houston last June, according to Rostad, the publication writes. One investor, for example, pointed to the problem of disclosing the existence of additional fees rather than the fees themselves, according to FA magazine.
“How are you going to be able to put fee information into that form to a degree that it has any meaning? For example, those of us who have brokerage agreements with large brokerages, they may have hundreds of different fund families that each have their own individual fees. And all I can see … is, ‘fund families may have additional fees,'” the investor said at the Houston roundtable, according to the publication.