Form CRS (Customer Relationship Summary) is a standardized two-page disclosure document that all SEC-registered investment advisers and broker-dealers must provide to retail investors. Implemented in June 2020 under SEC Rule 17a-14 and amendments to Form ADV, Form CRS is designed to help investors understand the services, fees, conflicts, and standards of conduct of their financial professional. Even high-net-worth individuals are classified as «retail investors» under SEC rules and are entitled to receive Form CRS. Asset Manager Tech LLC, as a SEC-registered RIA, provides Form CRS to all clients as part of our commitment to fiduciary transparency and regulatory compliance.Web Content Redesign for A_C Management Tech.pdf+1sec+6
What is Form CRS and Why Was It Created?
Form CRS was adopted by the Securities and Exchange Commission in June 2019 as part of the Regulation Best Interest (Reg BI) regulatory package, with compliance obligations beginning June 30, 2020. The SEC created Form CRS—technically designated as «Form ADV Part 3» for investment advisers—to address a fundamental information asymmetry in the financial services industry.klgates+3
Before Form CRS, investors faced inconsistent, often voluminous disclosure documents that made comparing advisers and brokers nearly impossible. Different firms used varied formats, lengths, and terminology to describe their services, creating confusion about the critical differences between brokerage (transaction-based) and advisory (relationship-based) services. The SEC designed Form CRS to provide standardized, concise disclosure that enables investors to make informed comparisons.ropesgray+2
Key Features of Form CRS:
- Maximum two pages for standalone investment advisers or broker-dealers; four pages for dual registrantssec+2
- Plain English requirement written at retail investors’ level of financial experience, avoiding legal jargon and technical termscorecls+2
- Prescribed order and standardized headings across all relationship summaries to facilitate comparisonsec+1
- Mandatory «conversation starter» questions designed to prompt dialogue between investors and financial professionalsreged+2
- Filed electronically with SEC via IARD system and publicly accessible on Investment Adviser Public Disclosure (IAPD) databasesec+1
The retail investor definition is deliberately broad: all natural persons who seek services primarily for personal, family, or household purposes, regardless of net worth or sophistication. This means an ultra-high-net-worth individual with $50 million in assets remains a retail investor entitled to receive Form CRS if investing for personal purposes rather than through a corporate entity.law.cornell+2
Asset Manager Tech files Form CRS as Form ADV Part 3 and delivers it to all prospective clients before or at the time we enter into an investment advisory contract. Our Form CRS is also posted on our website and available through the SEC’s public database.Website Marketing and Advertising Considerations.docx+1comply+1
A|C Management Tech LLC: Our Commitment to Fiduciary Duty as an SEC-Registered Adviser
What Information Must Be Disclosed in Form CRS?
Form CRS requires five mandatory sections presented in prescribed order, each addressing specific aspects of the adviser-client relationship. The standardized format enables investors to compare firms systematically rather than searching through lengthy brochures for critical information.irionline+3
Section 1: Introduction
The opening section establishes the firm’s registration status and sets context for the document. It must include standardized language: «Brokerage and investment advisory services and fees differ and it is important for you to understand the differences». Investment advisers state they are registered with the SEC or state securities regulators, while broker-dealers note their FINRA registration. The introduction also references the SEC’s free Investor.gov/CRS tool where investors can research firms and financial professionals.klgates+2
Section 2: Relationships and Services
This section answers the question «What investment services and advice can you provide me?» and requires disclosure of:comply+1
- Principal services offered (discretionary portfolio management, financial planning, execution-only services)
- Account monitoring frequency (continuous monitoring versus periodic reviews)
- Investment authority (discretionary decision-making versus requiring client approval for each trade)
- Investment offerings and any limitations (for example, «We focus exclusively on U.S. equities using algorithmic strategies»)
- Account minimums and client qualifications
Asset Manager Tech discloses that we provide discretionary portfolio management exclusively through our digital platform, with continuous algorithmic monitoring and a $500,000 account minimum. This section must also include the conversation starter: «Given my financial situation, should I choose an investment advisory service? Why or why not? How will you choose investments to recommend to me?».marottaonmoney+2[ppl-ai-file-upload.s3.amazonaws]
“We wouldn’t have gotten to where we are today without Finovate. The Finovate spent time with us to better understand our processes and where our bottlenecks were.”
Section 3: Fees, Costs, Conflicts, and Standard of Conduct
This comprehensive section addresses three critical areas:irionline+1
Fees and Costs: Advisers must describe principal fees including assets-under-management percentages, performance-based arrangements, hourly rates, or flat fees. The disclosure must also cover other costs such as transaction fees, custodian charges, and fund expenses. Form CRS cross-references Form ADV Part 2A Items 5A through 5D for complete fee details. The required conversation starter asks: «Help me understand how these fees and costs might affect my investments. If I give you $10,000 to invest, how much will go to fees and costs, and how much will be invested for me?».comply+3
Standard of Conduct: Investment advisers must include this mandated language: «When we act as your investment adviser, we have to act in your best interest and not put our interest ahead of yours». This fiduciary duty disclosure distinguishes RIAs from broker-dealers operating under Regulation Best Interest, which applies a transaction-by-transaction standard.luthor+2
Conflicts of Interest: Firms must disclose material conflicts including third-party payments, proprietary products, affiliated entities, and compensation structures that create misaligned incentives. Vague statements like «we may have conflicts» are insufficient; the SEC requires specific disclosure. The conversation starter prompts: «How might your conflicts of interest affect me, and how will you address them?».sec+3
Section 4: Disciplinary History
This section requires a simple yes or no answer to «Do you or your financial professionals have legal or disciplinary history?». Firms must provide a link to the SEC’s free search tool at Investor.gov where retail investors can investigate the complete disciplinary record of both the firm and individual professionals. The conversation starter asks: «As a financial professional, do you have any disciplinary history? For what type of conduct?».marottaonmoney+3
Section 5: Additional Information
The final section explains how to obtain more information about the firm’s services, including website, phone number, and email. It must reference Form ADV Part 2A as the comprehensive disclosure document and explain how to request an up-to-date copy of Form CRS. The conversation starter asks: «Who is my primary contact person? Is he or she a representative of an investment adviser or a broker-dealer? Who can I talk to if I have concerns about how this person is treating me?».reged+3
Form CRS vs. Form ADV Part 2A: What’s the Difference?
Form CRS and Form ADV Part 2A work together as «layered disclosure»—Form CRS provides a high-level executive summary while Form ADV Part 2A offers comprehensive detail. Understanding the relationship between these documents is essential for thorough due diligence.worthingtonwealth+1
|
Dimension |
Form CRS (ADV Part 3) |
Form ADV Part 2A |
|
Length |
Maximum 2 pages (standalone RIA); 4 pages for dual registrants sec+1 |
Typically 20-40+ pages depending on firm complexity [worthingtonwealth] |
|
Audience |
All retail investors (natural persons) irionline+2 |
All clients and prospective clients [worthingtonwealth] |
|
Content Scope |
High-level summary: services, fees, conflicts, disciplinary history irionline+1 |
Comprehensive: Items 4-19 covering business practices, strategies, fees, conflicts, custody, brokerage, performance comply+1 |
|
Format |
Standardized SEC-prescribed questions and sequence sec+1 |
Flexible format following Form ADV Part 2A instructions [worthingtonwealth] |
|
Delivery Timing |
Before or at time of entering advisory contract sec+1 |
Before or at time of entering advisory contract [worthingtonwealth] |
|
Update Requirements |
Within 30 days of any material change [sec] |
Annually within 90 days of fiscal year end [worthingtonwealth] |
|
Filing Method |
Filed with SEC via IARD as Form ADV Part 3 sec+1 |
Filed with SEC via IARD as Form ADV Part 2A [comply] |
|
Public Availability |
SEC IAPD database; often posted on firm websites sec+1 |
SEC IAPD database; required on firm websites worthingtonwealth+1 |
Form CRS includes strategic cross-references directing readers to specific sections of Form ADV Part 2A for deeper information. For example, Form CRS Item 2.C cross-references Form ADV Part 2A Items 4 and 7 regarding services and client types, while Form CRS Item 3.A(iii) directs readers to Form ADV Part 2A Items 5A through 5D for complete fee schedules.comply+1
Best practices for high-net-worth investors conducting due diligence: read Form CRS for all candidates to create a shortlist, then request and carefully review the full Form ADV Part 2A brochure for your top two to three finalists. Use Form CRS as an efficient «table of contents» to navigate the more detailed Form ADV Part 2A.worthingtonwealth+2
Asset Manager Tech’s Form CRS and Form ADV Part 2A are both publicly available on our website and the SEC’s Investment Adviser Public Disclosure (IAPD) database, ensuring complete transparency for prospective clients.Web Content Redesign for A_C Management Tech.pdf+1[sec]
Why Form CRS Matters for High-Net-Worth Investors
The SEC deliberately defined «retail investor» to include all natural persons without exclusion for net worth or sophistication. The regulatory rationale: «all individual investors would benefit from clear and succinct disclosure regarding key aspects of available brokerage and advisory relationships». An ultra-high-net-worth individual with $50 million remains a retail investor if investing for personal, family, or household purposes rather than through a corporate entity.law.cornell+2
Fee Transparency Becomes Critical at Scale
For accounts ranging from $500,000 to $10 million or more, seemingly small differences in fee structures compound dramatically over time. The Form CRS conversation starter—»If I give you $10,000 to invest, how much will go to fees and costs, and how much will be invested for me?»—forces advisers to quantify costs with precision.kitces+3
Consider the difference between a traditional 1% AUM fee and a performance-based structure on a $2 million account. The AUM fee generates $20,000 annually regardless of performance, while a 35% performance-based fee on $200,000 of gains produces $70,000 in adviser compensation but charges zero if the portfolio remains flat or declines. Form CRS makes these structural differences transparent, enabling sophisticated comparison.smartasset+3[ppl-ai-file-upload.s3.amazonaws]
Material Conflicts Require Specific Disclosure
Form CRS demands more than boilerplate language about conflicts. The most common material conflicts affecting high-net-worth investors include:sec+1
- Proprietary products or affiliated investment funds where the adviser earns additional compensation
- Dual registration as both broker-dealer and investment adviser, creating competing incentive structures
- Third-party payments including revenue sharing arrangements and 12b-1 fees
- Principal trading where the firm acts as counterparty to client trades
- Performance-based fee arrangements that may incentivize excessive risk-taking
The SEC requires firms to explain not only what conflicts exist but how the firm addresses them. Vague statements like «we may have conflicts of interest» signal inadequate disclosure; investors should read the full Form ADV Part 2A for specifics.sec+3
Fiduciary Standard Confirmation
Form CRS explicitly states whether the firm operates under the fiduciary standard (investment advisers) or the Regulation Best Interest standard (broker-dealers). For high-net-worth individuals seeking holistic wealth management—including tax planning, estate coordination, and multi-generational strategies—the continuous fiduciary standard represents the gold standard of obligation.sec+3
Asset Manager Tech’s Form CRS clearly discloses: «When we act as your investment adviser, we have to act in your best interest and not put our interest ahead of yours. At the same time, the way we make money creates some conflicts with your interests». This honest acknowledgment followed by specific conflict disclosure demonstrates transparency.[ppl-ai-file-upload.s3.amazonaws]irionline+1
Disciplinary History Verification
Form CRS includes a yes or no disclosure plus a direct link to Investor.gov for complete verification. High-net-worth investors should independently verify disciplinary history on the IAPD database before engaging any adviser. While a clean record does not guarantee ethical behavior, a history of violations—particularly those involving client funds, fraudulent representations, or fiduciary breaches—represents a clear warning signal.sec+2
Five Questions HNWIs Should Ask After Reading Form CRS:
- Does the fee structure align the adviser’s compensation with my investment success, or do they profit regardless of performance?kitces+1
- What specific conflicts does the adviser face, and what concrete steps do they take to manage those conflicts?irionline+1
- Does the adviser operate under continuous fiduciary duty, or a transaction-based suitability standard?luthor+1
- Has the firm or its principals been subject to regulatory discipline, and what was the nature of the violation?sec+1
- What additional costs beyond the stated advisory fee will I incur (trading costs, custodian fees, fund expenses)?[irionline]
Our Form CRS clearly discloses our performance-based fee structure (35% of net profits), our exclusive focus on algorithmic U.S. equity management, and our zero-tolerance policy for undisclosed conflicts. We embrace Form CRS requirements as consistent with our commitment to transparency.Asset_Manager_Partners_En.pdf+2
Achieving Your Vision
Planning for retirement is essential to your long-term financial well-being. At Finovate, our experienced team collaborates with you to identify your retirement goals and crafts a tailored, comprehensive strategy to help you achieve them with confidence.
How to Access and Evaluate Form CRS Before Choosing an RIA
Obtaining and systematically evaluating Form CRS should be the first step in any adviser selection process. The SEC designed Form CRS specifically to enable efficient comparison shopping before committing to a relationship.ropesgray+2
Where to Find Form CRS
Directly from the Investment Adviser: Advisers are legally required to deliver Form CRS before or at the time you enter into an advisory contract. If a prospective adviser refuses to provide Form CRS upfront or insists you must first sign an agreement, this constitutes a regulatory violation and a significant red flag.klgates+2
SEC Investment Adviser Public Disclosure (IAPD) Database: All filed Form CRS documents are publicly accessible at adviserinfo.sec.gov. This official database allows you to verify that the Form CRS you received matches the version filed with regulators.[sec]
Adviser’s Website: Many RIAs post Form CRS prominently in footer compliance links alongside Form ADV Part 2A, privacy policies, and business continuity plans. Asset Manager Tech includes direct access to our Form CRS and complete Form ADV brochure on every page of our website.[comply]Website Marketing and Advertising Considerations.docx+1
Six-Step Form CRS Evaluation Process
Step 1: Verify Registration Status
Confirm the adviser is specifically «SEC-registered» or state-registered, not merely using the generic term «financial adviser». Note whether the firm is a dual registrant operating as both broker-dealer and investment adviser, which increases potential for conflicting incentives.[irionline]
Step 2: Assess Service Alignment
Verify that the services described match your wealth management needs. Does the adviser offer discretionary management, or do they require approval for each trade? Do they provide financial planning, tax advice, and estate coordination, or only investment management? Check investment limitations—if you need international diversification but the adviser focuses exclusively on U.S. equities, misalignment exists.[ppl-ai-file-upload.s3.amazonaws][irionline]
Step 3: Calculate Fee Impact
Estimate your approximate annual costs based on your account size and expected returns. For a $2 million account, calculate what a 1% AUM fee ($20,000) versus a 35% performance fee (variable based on gains) would mean over one, five, and ten years under different performance scenarios. Identify all additional costs including transaction fees, custodian charges, and underlying fund expenses.smartasset+2
Step 4: Scrutinize Conflicts
Look for specific conflict disclosures rather than vague boilerplate language. Ask the follow-up question: «How does your compensation structure create conflicts with my interests, and what controls do you have in place to manage those conflicts?». A firm claiming «we have no material conflicts» likely lacks transparency—every business model creates some conflicts; the question is disclosure and management.reged+3
Step 5: Verify Disciplinary Record
If Form CRS indicates «Yes» to disciplinary history, immediately visit Investor.gov/CRS and the IAPD database for complete details. Understand the nature of the violation: was it an administrative paperwork issue or allegations of fraud, misappropriation, or fiduciary breach?. Multiple violations or a pattern of similar complaints warrant serious concern.sec+2
Step 6: Request Form ADV Part 2A
After using Form CRS to narrow your list to two or three finalists, request the complete Form ADV Part 2A brochure from each. Pay particular attention to Item 8 (methods of analysis and investment strategies), Item 11 (code of ethics and personal trading), Item 12 (brokerage practices), and Item 14 (client referrals and other compensation).worthingtonwealth+1
Red Flags When Reviewing Form CRS
- Adviser refuses to provide Form CRS until after you sign an agreement[sec]
- Form CRS exceeds two pages for standalone adviser (indicates non-compliance)klgates+1
- Vague or incomplete answers to required questionssec+1
- Adviser dismissive when asked about disclosed disciplinary history[irionline]
- Fee structure unclear or buried in footnotes and fine print[irionline]
- Conflicts section contains only boilerplate language without specific disclosures[sec]
- Conversation starter questions missing or not properly formatted for prominencemarottaonmoney+1
Access Asset Manager Tech’s Form CRS and Form ADV Part 2A to review our complete disclosures before making any commitment.Website Marketing and Advertising Considerations.docx+1
Transparency as Foundation for Fiduciary Relationships
Form CRS represents a significant advance in investor protection, providing standardized, plain-English disclosure that enables sophisticated investors to compare advisers efficiently. While all natural persons are classified as retail investors under SEC rules, high-net-worth individuals benefit particularly from Form CRS’s transparency requirements regarding fees, conflicts, and fiduciary standards.federalregister+5
Asset Manager Tech embraces this regulatory framework as entirely consistent with our commitment to transparency and fiduciary accountability. Our Form CRS clearly discloses our performance-based fee structure (35% of net profits, zero fees in negative years), our algorithmic investment approach focused exclusively on U.S. equities, and our unwavering fiduciary duty to act exclusively in your best interest. We maintain no proprietary products, accept no third-party payments, and structure our custody arrangements through Interactive Brokers to ensure complete separation of client assets.Marketing and Advertising Policy. Sample.docx+2
We encourage prospective clients to review our Form CRS alongside our comprehensive Form ADV Part 2A as part of their due diligence process. Both documents are publicly available on our website and through the SEC’s Investment Adviser Public Disclosure database, providing complete transparency before you make any commitment.comply+2[ppl-ai-file-upload.s3.amazonaws]
Learn more about our approach:
- Review our Form CRS (Form ADV Part 3)
- Read our complete Form ADV Part 2A Brochure
- Understand our fiduciary standard
- Learn about our algorithmic investment approach
- Contact us with questions about our services
Risk Disclosure
Investing involves risk, including possible loss of principal. Past performance is not indicative of future results. Asset Manager Tech LLC is an SEC-registered investment adviser. Registration does not imply a certain level of skill or training. This content is for educational and informational purposes only and does not constitute investment advice, an offer to provide investment advisory services, or a solicitation. For complete information about our services, fees, potential conflicts of interest, and disciplinary history, please review our Form CRS and Form ADV Part 2A. You may also access these documents via the SEC’s Investment Adviser Public Disclosure (IAPD) database at adviserinfo.sec.gov.sec+2Marketing and Advertising Policy. Sample.docx+1