On April 12, 2018, the Office of Compliance Inspections and Examinations (“OCIE”) issued a National Exam Program risk alert in which it outlined the most frequent advisory fee and expense compliance issues identified in deficiency letters sent to SEC-registered investment advisers. To read the full risk alert, click here. The six most frequent areas of concern noted were: Fee-Billing Based on Incorrect Account Valuations – for example, using a different metric or process than was specified in the client agreement or

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On April 6, 2018, the SEC ordered three Registered Investment Advisers (RIAs) to pay $12 million to clients harmed by the firms’ breach of their fiduciary obligations. The RIAs had generated millions of dollars in improper fees by selecting higher-cost mutual fund shares for clients, even though less expensive ones were available. In total, the three RIAs were ordered to pay nearly $15 million. The SEC’s orders stated that the RIAs failed to disclose conflicts of interest and violated their

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