California-based SEC RIA fined over Form CRS failures
This matter involves Carmel Capital’s failure to file with the Commission and to deliver to retail investor clients its Form CRS. Carmel Capital was required to file its initial Form CRS with the Commission as Part 3 of its Form ADV and to begin delivering its Form CRS to prospective and new retail investor clients, as applicable, by June 30, 2020. Carmel Capital was further required to deliver its Form CRS to existing retail investor clients by July 30, 2020. The firm failed to file and deliver Form CRS by these deadlines, not becoming compliant until in or after late January 2021.