Risk Alert: Review Advisory Fee Calculations for the 2021 Audit Season (before the SEC does)
The U.S. Securities and Exchange Commission (SEC) has publicly stated that advisory fees and how fees are assessed, calculated, and disclosed to potential investors in the offering memorandums or financial statements will be an area of focus for 2022. In November 2021, the SEC Division of Examination issued a Risk Alert dealing with deficiencies noted in the examination of several hundred retail advisors. The SEC Staff believe that the issue arose because of poor policies and procedures over the advisory fee calculation and billing area. Numerous errors in the calculation, and disclosure-related issues, were discovered in the advisory fee area. In…