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The SEC's Office of Compliance Inspections and Examinations published a risk alert outlining the most common compliance issues relating to advisory fees and expenses its staff encountered during their examinations.
The SEC's Office of Compliance Inspections and Examinations
published a risk alert outlining the most common compliance issues
relating to advisory fees and expenses its staff encountered during
their examinations. The most frequently identified deficiencies
included:
Fee-billing based on incorrect
account valuations;
Billing fees in advance or with
improper frequency;
Applying the incorrect fee rate;
Omitting rebates and incorrectly
applying discounts;
Disclosure issues involving advisory
fees; and
Adviser expense misallocations.
OCIE encouraged advisers to review their practices, policies and
procedures to ensure compliance with their advisory agreements and
representations to clients regarding fees and expenses made in Form
ADV and other disclosures.
The content of this article is intended to provide a general
guide to the subject matter. Specialist advice should be sought
about your specific circumstances.
