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Form CRS builder

Pick the firm type, answer the items the Form CRS instructions require, and get a draft relationship summary in the required order, with the required headings, statements and conversation starters word for word and your own answers in plain sentences around them. It opens on a worked Form CRS example for a small adviser, checks the draft against the page limit, and copies or prints as a template to finish. A drafting aid, not a filing: your compliance counsel reviews it.

Form CRS limits and clocks

  • Paper length, adviser or broker-dealer2 pages
    Form CRS Instructions, General Instruction 1.C
  • Paper length, dual registrant, one summary4 pages
    Form CRS Instructions, General Instruction 1.C
  • Items, answered in this order5
    Form CRS Instructions, General Instruction 1.B
  • File an update after information becomes materially inaccurate30 days
    Form CRS Instructions, General Instruction 8.A
  • Tell existing clients what changed60 days
    Form CRS Instructions, General Instruction 8.B
  • Deliver on request30 days
    17 CFR 275.204-5(b)(5); 17 CFR 240.17a-14(c)(5)
  • Broker-dealer keeps each Form CRS, at least6 years
    17 CFR 240.17a-4(e)(10)
From the SEC’s Form CRS instructions (SEC 2942 (05-20)) and the eCFR text of Rules 204-5, 17a-14 and 17a-4, read October 22, 2026. Not legal advice.
Stipple engraving of a folded two-panel blank card standing beside a card box and a pen
Card 01
A relationship summary is short by rule: two pages, or four for a dual registrant’s single summary.

What it computes

Form CRS is the relationship summary that SEC-registered advisers and broker-dealers must give retail investors: a natural person, or a natural person’s legal representative, who seeks or receives services primarily for personal, family or household purposes. A firm with no retail investors to deliver one to does not prepare or file one. Advisers file it as Part 3 of Form ADV through IARD (the guide to Form ADV covers the other parts); broker-dealers file it through FINRA’s Web CRD.

The builder answers the Form CRS requirements in the order the instructions set: five items, every one answered, nothing added that the instructions do not require or permit. It writes three kinds of words, and the draft marks each block in its margin so a reviewer can see which is which.

  • Required wording: headings, conversation starters, the fees statement and the standard of conduct, copied word for word for your firm type
    Items 2.A, 2.D, 3.A, 3.B, 3.C, 4.A, 4.D, 5.C
  • The instructions’ words, adapted: sentences the instructions describe in their own words, turned into the “you” voice
    General Instruction 2.A
  • From your answers: services, fees, conflicts and contacts, assembled into plain sentences you rewrite
    Items 2.B, 3.A.(i), 3.B.(ii), 3.C, 5.A, 5.B

It then estimates the length against the page limit: two pages for an adviser or a broker-dealer, four for a dual registrant that puts both businesses in one summary. The instructions measure pages, not words, so the estimate rests on a stated assumption and the warning comes early. The detailed disclosures the summary points to are the brochure’s job; the Form ADV Part 2A and 2B guide covers them.

Worked example

The tool opens on a Form CRS example: Example Advisers LLC, a small SEC-registered adviser offering portfolio management and financial planning, with discretionary and non-discretionary accounts, an asset-based fee and a fixed planning fee, no disciplinary history and one conflict to disclose, the incentive to recommend a rollover. Its draft runs to about 803 words, about 1.5 of its 2 pages by the tool’s estimate. Item 3 is the longest at 404 words: it carries three required headings, the fees statement and the standard of conduct word for word.

Switch the firm type and five things change at once. The table shows them, taken from the same wording the tool uses.

What the firm type changes

Required Form CRS wording by firm type
ElementInvestment adviserBroker-dealerDual registrant, one summary
Page limit, paper2 pages2 pages4 pages
Registered as (Item 1.A)an investment advisera broker-dealerboth a broker-dealer and an investment adviser
First conversation starter (Item 2.D)Given my financial situation, should I choose an investment advisory service? Why or why not?Given my financial situation, should I choose a brokerage service? Why or why not?Given my financial situation, should I choose an investment advisory service? Should I choose a brokerage service? Should I choose both types of services? Why or why not?
Item 3.B heading, first questionWhat are your legal obligations to me when acting as my investment adviser?What are your legal obligations to me when providing recommendations?What are your legal obligations to me when providing recommendations as my broker-dealer or when acting as my investment adviser?
Standard of conduct, first sentence (Item 3.B.(i))When we act as your investment adviser, we have to act in your best interest and not put our interest ahead of yours.When we provide you with a recommendation, we have to act in your best interest and not put our interest ahead of yours.When we provide you with a recommendation as your broker-dealer or act as your investment adviser, we have to act in your best interest and not put our interest ahead of yours.

Form CRS Instructions, Items 1.A, 2.D, 3.B, 3.B.(i); General Instruction 1.C. Standard of conduct shown for a broker-dealer that makes Regulation Best Interest recommendations.

The rule text

Three sentences of the general instructions decide the shape of every draft: the order, the length, and when the required words may change.

The builder never changes required wording on its own; where a sentence does not fit your firm, that is a call for you and your compliance counsel under the last sentence above. The rest of the drafting rules are about tone: plain English, short sentences, active voice, and the summary written as if speaking to the retail investor, with “you” and “us” (General Instruction 2.A). Conversation starters, and the references to more detailed information, must stand out from the text around them (General Instructions 4.A and 4.C).

Where the rule says so

Each item, paragraph by paragraph, with the wording it requires word for word. Open a row to read it. The full text is the SEC’s Form CRS instructions (SEC 2942 (05-20)).

Item 1. Introduction
  • Item 1

    The date, prominently at the beginning (in the header or footer of the first page, or the electronic equivalent).

  • Item 1.A

    Your name; whether you are registered with the SEC as a broker-dealer, investment adviser, or both; and that brokerage and investment advisory services and fees differ and it is important for the retail investor to understand the differences. A reference to FINRA or SIPC membership is allowed.

  • Item 1.B

    That free and simple tools are available to research firms and financial professionals at Investor.gov/CRS, which also provides educational materials.

Item 2. Relationships and Services
  • Item 2.A

    The heading.

    “What investment services and advice can you provide me?”

  • Item 2.B

    Whether you offer brokerage services, investment advisory services, or both; the principal services, accounts or investments; and material limitations. Broker-dealers state their principal brokerage services, including buying and selling securities, and whether they offer recommendations.

  • Item 2.B.(i)-(iv)

    Monitoring (whether, how often, limits, whether standard); investment authority (discretion and its triggers and limits, or that the retail investor makes the ultimate decision); limited investment offerings; account minimums and other requirements.

  • Item 2.C

    Specific references to more detailed information about your services: at least what Form ADV Part 2A Items 4 and 7 (or Appendix 1 Items 4.A and 5) and Regulation Best Interest require, as applicable.

  • Item 2.D

    Conversation starters. The first depends on the firm type; (iv) and (v) apply to every firm.

    Investment adviser“Given my financial situation, should I choose an investment advisory service? Why or why not?”

    Broker-dealer“Given my financial situation, should I choose a brokerage service? Why or why not?”

    Dual registrant, one summary“Given my financial situation, should I choose an investment advisory service? Should I choose a brokerage service? Should I choose both types of services? Why or why not?”

    Every firm“How will you choose investments to recommend to me?”

    Every firm“What is your relevant experience, including your licenses, education and other qualifications? What do these qualifications mean?”

Item 3. Fees, Costs, Conflicts, and Standard of Conduct
  • Item 3.A

    The heading.

    “What fees will I pay?”

  • Item 3.A.(i)-(ii)

    The principal fees and costs, how often they are assessed and the conflicts they create (broker-dealers: transaction-based fees; advisers: the fee types reported in Form ADV Part 1A, Item 5.E); then examples of the most common other fees and costs.

  • Item 3.A.(iii)

    This statement, word for word, and specific references to more detailed fee information.

    “You will pay fees and costs whether you make or lose money on your investments. Fees and costs will reduce any amount of money you make on your investments over time. Please make sure you understand what fees and costs you are paying.”

  • Item 3.A.(iv)

    Conversation starter.

    “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?”

  • Item 3.B

    The heading, by firm type.

    Investment adviser“What are your legal obligations to me when acting as my investment adviser? How else does your firm make money and what conflicts of interest do you have?”

    Broker-dealer“What are your legal obligations to me when providing recommendations? How else does your firm make money and what conflicts of interest do you have?”

    Dual registrant, one summary“What are your legal obligations to me when providing recommendations as my broker-dealer or when acting as my investment adviser? How else does your firm make money and what conflicts of interest do you have?”

  • Item 3.B.(i)

    The standard of conduct, emphasis required. Broker-dealers and dual registrants that do not make Regulation Best Interest recommendations use a different version.

    Investment adviser“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. You should understand and ask us about these conflicts because they can affect the investment advice we provide you. Here are some examples to help you understand what this means.”

    Broker-dealer“When we provide you with a recommendation, 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. You should understand and ask us about these conflicts because they can affect the recommendations we provide you. Here are some examples to help you understand what this means.”

    Dual registrant, one summary“When we provide you with a recommendation as your broker-dealer or 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. You should understand and ask us about these conflicts because they can affect the recommendations and investment advice we provide you. Here are some examples to help you understand what this means.”

  • Item 3.B.(ii)

    Where they apply, proprietary products, third-party payments, revenue sharing and principal trading, with the incentive each creates; if none applies, at least one other material conflict.

  • Item 3.B.(iii)-(iv)

    A conversation starter, then specific references to more detailed information about conflicts.

    “How might your conflicts of interest affect me, and how will you address them?”

  • Item 3.C

    The heading, then how financial professionals are paid (cash and non-cash) and the conflicts it creates, including the factors listed in 3.C.(ii) where they apply.

    “How do your financial professionals make money?”

Item 4. Disciplinary History
  • Item 4.A

    The heading.

    “Do you or your financial professionals have legal or disciplinary history?”

  • Items 4.B-4.C

    “Yes” if you or any financial professional discloses, or is required to disclose, disciplinary information on Form ADV, Form BD, or Forms U4, U5 or U6 (to the extent released to BrokerCheck); otherwise “No”.

  • Item 4.D

    Whatever the answer, direct the retail investor to Investor.gov/CRS for a free and simple search tool, and add the conversation starter.

    “As a financial professional, do you have any disciplinary history? For what type of conduct?”

Item 5. Additional Information
  • Items 5.A-5.B

    Where the retail investor can find more about your services and request a copy, prominently at the end, and a telephone number for up-to-date information and copies.

  • Item 5.C

    Conversation starter.

    “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?”

Filing, delivery and updates

A finished summary is filed, delivered and kept current on clocks the rules set. Advisers file it as Form ADV Part 3 with IARD and broker-dealers through Web CRD; a dual registrant serving retail investors on both sides files with both, in a text-searchable format with machine-readable headings. The Form ADV annual amendment planner dates the adviser’s yearly filing, and the RIA and FINRA compliance checklist puts Form CRS beside the rest of a firm’s program.

  • Adviser: deliver before or at the time you enter into an investment advisory contract
    17 CFR 275.204-5(b)(1)
  • Broker-dealer: before or at the earliest of a recommendation, an order, or opening a brokerage account
    17 CFR 240.17a-14(c)(1)
  • Existing clients: again at a new account, a rollover recommendation, or a new service or investment
    17 CFR 275.204-5(b)(2); 17 CFR 240.17a-14(c)(2)
  • Post the current summary prominently on your website, if you have one
    17 CFR 275.204-5(b)(3); 17 CFR 240.17a-14(c)(3)
  • Deliver on request30 days
    17 CFR 275.204-5(b)(5); 17 CFR 240.17a-14(c)(5)

Keep what you deliver. An adviser keeps a copy of each Form CRS and each amendment, and a record of the dates it was given, under Rule 204-2(a)(14)(i); a broker-dealer records each delivery date under Rule 17a-3(a)(24) and keeps those records, and a copy of each Form CRS, for at least six years after each is created under Rule 17a-4(e)(10). The retention calculator counts those periods, and the guides to Rule 204-2 and to FINRA compliance for small broker-dealers cover the record rules around it. A firm that would rather track versions and delivery dates in software can read the comparison of RIA compliance software.