"[T]he staff of the Division of Investment Management and the Division of Trading and Markets [has published FAQs] about the disclosure requirements of Form CRS with respect to a firm's disciplinary and legal history.... [T]he FAQs state that a firm's relationship summary may not omit the disciplinary history section in its entirety or omit the disciplinary history with respect to either a firm or its financial professionals, even when there is no such reportable disciplinary history.... Additionally, the FAQs state that Form CRS does not preclude firms or their financial professionals from providing separately copies of additional regulatory disclosures directly to a retail investor."

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