Unfortunately, in a very short sighted move by the United States Securities and Exchange Commission, its Chairman Jay Clayton announced that the SEC would not extend the compliance date for Regulation BI and the use of Form CRS passed the deadline of June 30, 2020.
Apparently, Chairman Clayton has not seen the recent Covid-19 numbers as well as the fact most broker-dealers have employees working from home. Instead, he stated that the SEC’s Office of Compliance Inspections and Examinations as well as FINRA are finalizing plans for examinations to take place (we suppose the exams will be virtual given the stay at home orders), and that, in his humble opinion, firms are well on their way to ensuring compliance. Essentially, why stop the bus now since it is already on route to its destination.
Sadly, in this trying time, firms are going to have continue to dedicate resources when many have been working remotely to keep their businesses afloat. Of course, counsel is here to assist these firms in ensuring compliance with Regulation BI and the preparation of Form CRS.