The staff from Division of Examinations (the “Division”) often reviews whether advisers, among other things: have adopted and are following policies and procedures that are reasonably designed to result in the fair and accurate charging of fees; and have disclosed their fees with sufficient clarity for their clients to understand the costs associated with their services. The Division previously published a Risk Alert highlighting compliance issues observed by the staff related to advisory fees (“Advisory Fees Risk Alert”). In this follow up Risk Alert, the Division is supplementing the Advisory Fees Risk Alert by providing greater detail on certain compliance issues observed during the recent Advisory Fees Initiative examinations, including additional details regarding the staff’s observations concerning fee-related deficiencies and fee-related compliance and disclosure issues.

View the Risk Alert: Division of Examinations Observations: Investment Advisers’ Fee Calculations