By Doug Fritz
It has been about a year since the U.S. Securities and Exchange Commission announced a risk alert that “Most Frequent Advisory Fee and Expense Compliance Issues Identified in Examinations of Investment Advisers.” Such inappropriate fee billing and expense practices may violate the Investment Advisers Act of 1940 and the rules implementing it, including anti-fraud provisions. Since the SEC announced the risk alert, there have been numerous fines and penalties charged to firms who have overbilled clients, whether intentional or not.
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