Firm Settles FINRA Charges for Form CRS Disclosure Failures

A firm settled FINRA charges for willfully failing to file and deliver an accurate Customer Relationship Summary form ("Form CRS") to retail investors. 

According to the AWC, the firm failed to accurately respond to Item 4 of Form CRS, which asks whether the firm or its financial professionals have legal or disciplinary history. Despite having a reportable history, the firm's initial filing failed to check "Yes" and omitted the required headings and "conversation starters" associated with that item.

FINRA found that the firm failed to correct these errors in subsequent years. In May 2023, the firm amended the form on its website—without filing it with the Central Registration Depository—but still failed to answer "Yes," stating instead that its associated persons had no disclosures while ignoring the firm's own history. In May 2025, the firm filed an amendment that explicitly answered "No" to the disciplinary history question. The firm did not file and deliver a compliant Form CRS until August 2025.

FINRA concluded that the firm willfully violated Exchange Act Section 17(a)(1) ("Records and Reports"), Exchange Act Rule 17a-14 ("Form CRS, for preparation, filing and delivery of Form CRS"), and FINRA Rule 2010 ("Standards of Commercial Honor and Principles of Trade"). 

The firm agreed to (i) a censure and (ii) a $20,000 fine.