Form CRS Attestation

The Form CRS Attestation is a Spire requirement that works in an effort to evidence the delivery of the Form CRS (Client Relationship Summary) and other disclosure documents to maintain compliance with Reg BI. This requirement for the CRS is needed every time a new recommendation is made, and when engaging a client in a new relationship. 

For example, if you open a joint account for a client today and obtain the Form CRS Attestation, and then 3 months later you open up an UGMA for their child, a new CRS must be delivered.  Please note that if the additional recommendation is made within 30 days of the initial CRS delivery, no new attestation is needed.

Evidence of delivery can be accomplished in one of the following three ways:

1. In Person/Mail: completion of the Form CRS Attestation that requires a client signature when submitting paperwork with the document delivery taking place at or prior to the recommendation.
2. Email: satisfaction of the requirement can also be fulfilled by providing Operations with a copy of the Sent Email to the client that documents that the disclosures were sent to the client’s email that is on file (or will be on file for new clients).
3. Docusign: Sending the disclosures via Docusign generates a unique stamp ID on the form that can be used to evidence delivery of the requirement.