Division of Examinations Observations: Investment Advisers’ Fee Calculations
This seems like an issue that never dies: advisers just can't calculate fees correctly! On Nov. 10, the SEC published a Risk Alert highlighting its findings from 130 examinations of advisers re: fee calculations. Briefly, the key deficiencies observed included: (1) advisory fee calculation errors, such as over-billing of advisory fees, inaccurate calculations of tiered or breakpoint fees, and inaccurate calculations due to incorrect householding of accounts; and (2) not crediting certain fees due to clients, such as prepaid fees for terminated accounts or pro-rated fees for on-boarding clients. In addition, the staff observed fee-related compliance and disclosure issues. The SEC specifically notes that this Risk Alert updates an earlier Alert (from 2018) and provides guidance on how advisers can improve compliance. Please click the headline to this summary to access the Risk Alert.