SEC Reg BI, Form CRS & Department of Labor (DOL) Fiduciary Rule

Understanding our relationship with you

As a Olympia LTD client, you are at the center of everything we do. That’s why it’s so important to us that you have a clear understanding of our services, how we operate, and the latest industry rules. So that when we make a recommendation, you can feel confident knowing we’re always putting your interests ahead of our own.

How we act in your best interest

Several standards and rules have been put in place to ensure that when our Financial Consultants make recommendations, they are indeed putting your needs first.

Regulation Best Interest (Reg BI):

As of June 30, 2020, a common standard was established that any brokerage firm or Registered Investment Advisor making an investment recommendation to you must be acting in your best interest at the time the recommendation is made.

Form CRS:

The SEC requires broker-dealers and investment advisors to provide you with a Form CRS to help you make more-informed decisions about choosing or continuing to work with them.

2020 Department of Labor (DOL) Advice Exemption (the Exemption):

When we provide investment advice to you regarding your retirement plan account or Individual Retirement Account (IRA), we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interests ahead of yours. This applies to the following Covered Account types:

• IRAs (including SEP and SIMPLE IRAs)

• 401(k) plans

• Individual 401(k)

• Qualified Retirement Plan (QRP) and Company Retirement Account (CRA)

Learn how Olympia LTD works to help investors

Resource

 

Description

 

Form

 

Form CRS

 
Designed as a simple, easy-to-understand Customer Relationship Summary, providing you with details of the nature of our relationship.

Regulation BI Disclosures

 
Regulation Best Interest Disclosure: Designed to give you a better understanding of how
Olympia LTD works with you in making investment recommendations.

Olympia LTD makes investment recommendations as to the following

Fixed income products

  • Consultation with our Fixed Income Sales (FIS) team to understand your income goals and needs. Customized recommendations as to:
    • Specific fixed income securities or investment vehicles
    • Fixed income investment strategies, such as bond ladders

 

 

Retirement accounts and rollovers

  •  Get help deciding about a rollover from your 401(k) or other retirement plan to an IRA
  • Or use the following resources to help you decide on your own:

        Considering a 401(k) Rollover?
        Rollover IRA
        Your Rollover Pocket Guide
        IRA Guide

  • Speak with a Financial Consultant for more information or for a recommendation

FAQ

No action is needed on your part. As of June 30, 2020, all clients are required to receive the Form CRS in advance of any recommendations.

Olympia LTD has always been committed to standing on the side of retail investors by empowering them with self-directed tools and educational materials. We have also strived to put our clients’ needs first and advocated for a best interest standard for all retail broker-dealers.

Reg BI is a rule issued by the SEC that requires broker-dealers and their associated persons to act in the best interest of the retail customer at the time an investment recommendation is made, without placing the financial or other interests of the broker-dealer ahead of the interests of the retail customer. This higher standard of conduct applies when recommending the following:

  • Securities transactions; or
  • Investment strategies involving securities, including account types; or
  • Opening an IRA or brokerage account; or
  • Rolling over assets from one account type to another

The rule also requires broker-dealers to identify and disclose potential conflicts of interest and financial incentives the broker-dealer may have in making these types of recommendations.

Reg BI was issued by the SEC to establish a higher conduct standard for broker-dealers when they are making investment recommendations.

Reg BI requires all brokerage firms that provide recommendations to retail investors to act in the investor’s best interest when making a recommendation. In addition, both brokerage firms and investment advisors are required to provide a disclosure to retail investors, the Form CRS (Customer Relationship Summary).

Reg BI went into effect on June 30, 2020.

Reg BI applies when broker-dealers are making a recommendation as to any type of retail brokerage account for retail investors as well as to investment advisory accounts.

Yes. Reg BI itself applies only to broker-dealers. Investment advisors are subject to their own requirements under the Investment Advisers Act of 1940. But the Form CRS requirements apply to both brokers and investment advisors.

Reg BI applies to investment recommendations made to prospective customers, new customers, and existing clients of Olympia LTD.

As defined in Regulation Best Interest, a “retail customer” is a natural person, or the legal representative of such natural person, who

  • receives a recommendation of any securities transaction or investment strategy involving securities from a broker-dealer, or a natural person who is an associated person of a broker-dealer, and
  • uses the recommendation primarily for personal, family, or household purposes.

As with other SEC rules, the Financial Industry Regulatory Authority (FINRA) examines and enforces compliance with Reg BI based upon SEC guidance. FINRA works with SEC staff to ensure consistency in examining a broker-dealer and their associated persons for compliance with Reg BI. The SEC’s Division of Examinations also conducts examinations which may lead to enforcement actions.

The Best Interest Disclosure (BID) is a customized document that

  • Indicates how Olympia LTD is acting as a fiduciary when making advice recommendations covered by the Exemption
  • Provides information regarding Financial Consultants’ compensation—and ways that compensation may create conflicts of interest
  • Lists specific reasons why the recommendation is in the client’s best interest
  • Discloses our fiduciary relationship

The Exemption requires BIDs to be sent at the time of the following types of recommendations: 

• Retirement Account Transfer recommendations

• Rollover recommendations

• Recommendations to enroll (or unenroll) in a managed investing solution (account conversions)

Specific types of recommendations could cause investors to incur higher costs than what they may have currently, including advisory fees or investment costs. The BID allows Financial Consultants to inform investors of the potential higher costs and how these costs may impact the value of their retirement account.

The Form CRS rule requires broker-dealers and Registered Investment Advisors to deliver to retail clients and prospects a brief relationship summary disclosing certain information about the firm(s). The Form CRS must contain five specific sections:

  • Introduction: This section clearly indicates that brokerage and investment advisory services and fees differ, and that it is important for a retail investor to understand the difference between the services and fees.
  • Relationships & Service – This describes the relationship and services offered, including a discussion of whether the firm provides account monitoring services, potential investment authority, any limitations on offerings, and account minimums.
  • Fees, Costs, Conflicts, and Standard of Conduct: Firms must provide detailed descriptions about the fees and costs that their retail investors will pay, their conflicts of interest, and the applicable standard of conduct in making investment recommendations to retail investors.
  • Disciplinary History: A firm must provide disclosures of disciplinary information regarding the firm and its financial professionals.
  • Additional information: A firm must provide instructions regarding where a retail investor can find more information about the firm and the services it offers.

If you are working with an investment advisor, as of June 30, 2020, you must receive a Form CRS before or at the time you and your advisor enter into an investment advisory relationship.

If you are working with a broker-dealer, you must receive the Form CRS at the earliest of the following: a recommendation of an account type, a securities transaction, or an investment strategy involving securities; the placing of an order for you; or the opening of a brokerage account for you.

The Form CRS is designed to educate you on our offerings, services, fees, and costs and to provide you with information you may need when asking questions and initiating a conversation with us and our representatives. The disclosure is intended to be in simple English, be easy to understand, and help facilitate a conversation between you and our financial representative.

Both documents will be sent separately when a Financial Consultant provides advice or a recommendation to a retirement investor.

The Best Interest Disclosure (BID) is an acknowledgment in writing of the firm’s and its investment professionals’ fiduciary status under Title I of ERISA and the Internal Revenue Code when providing investment advice to retirement investors. The BID goes into detail on the services provided, the material conflicts of interest, and the rationale for the recommendation.

Form CRS is a brief relationship summary disclosing certain information about the firm, including sections covering the following: Introduction; Relationships and Services; Fees, Costs, Conflicts, and Standard of Conduct; Disciplinary History; and Additional information. The goal of Form CRS is to provide information to help initiate questions and a conversation with our representatives on topics like our offerings, services, fees, and costs.

At Olympia LTD, we strive to put your needs first. We believe these rules help strengthen the relationship we have with our clients, by facilitating more open and straightforward dialog between you and
Olympia LTD.

This site is designed to provide you with information about your relationship with Olympia LTD, Inc. and Olympia LTD Investment Management, LLC as outlined by Reg BI and the Form CRS rule. You’ll find a number of different resources, including the applicable Form CRS and additional disclosures and details on Reg BI.