A number of former regulators and current policy experts asked the Securities and Exchange Commission today to revise Form CRS (customer relationship summary) to include not only “plain English,” but also actual average expense and compensation disclosure requirements.

In an ideal word the summary—which is central to the SEC’s retail advice rule Regulation Best Interest-- would tell investors whether a financial professional has a legal fiduciary obligation to put the investor’s interests first and what they’ll actually be charged for products and services, a panel of experts said at a Tuesday press conference hosted by the Institute for the Fiduciary Standard.

“The form is a widely-accepted failure in terms of how advisors differ from brokers,” said Institute President Knut Rostad. To fix it, the Institute is recommending a new two-page Form CRS and a mandatory letter that reps and advisors would be required to give to prospective customers detailing for the first time the actual average expenses and commissions or fees the investor will be charged.

“Investors have the right to know what this service or product is going to cost,” Rostad said. “It’s important to note that in any other industry, actual costs are disclosed. It’s only in broker-dealer sales and trading where the issue of what something will cost is permitted to be so hidden.”

Aron Szapiro, Head of Policy Research at Morningstar, Inc, said the firm “supports the Institute’s proposals for fee disclosures. Morningstar believes investors deserve clear, comparable, standardized disclosures listing advisory fees, commissions, loads, and any other relevant fees. For recommendations of a portfolio of mutual funds, brokers and RIAs should provide investors with the asset-weighted average expense ratio in addition to fund-specific expenses,” Szapiro said.

All-in costs are difficult to discern in the current Form CRS, but reps and advisors can fix that by using a system such as Morningstar Advisor Workstation to find registered product fees and calculate an automatic formulation of average costs, the Institute said.

In 2017, over 185,000 professionals at 170 distinct firms had access to Morningstar Advisor Workstation. The vast majority of the registered rep community can access the information needed to populate the Institute’s sample disclosure letter, according to the Institute.

Former Assistant Secretary of the DOL Phyllis Borzi said the SEC’s disclosure form “simply does not work. What is important is we have evidence we can make significant improvements without remaking the world or doing a major study just by using plain language.”

Former SEC Commissioner Luis Aguilar said that disclosures “that are vague and opaque fail to meet the needs of investors and create unnecessary confusion. Disclosures should be clear as to whether an advisor is – or is not – a fiduciary and what that difference means. Investors deserve no less.”

Rostad said he is in the process of requesting a meeting with SEC Chairman Gary Gensler and staff to press the Institute’s request for Form CRS revisions. While Gensler has told Congress that he intends to enforce Reg BI and by extension Form CRS as written, Rostad said he believes significant improvements can be made without extensive revisions.