Fee Billing

Core Concepts

1. Fee Schedule Structures

Advisory firms employ a range of fee structures, often combining several within a single practice.

Flat Fee (Fixed Dollar). A predetermined dollar amount charged per period regardless of account size. Common for financial planning engagements or retainer-based advice. Straightforward to bill but disconnected from asset growth.

AUM-Based (Percentage of Assets). The most prevalent model for registered investment advisers. A single percentage (e.g., 1.00%) is applied to the market value of managed assets. Simple to communicate but can become expensive for large portfolios and cheap for small ones.

Tiered / Breakpoint (Declining Rate). A graduated schedule where successive tiers of assets are billed at progressively lower rates. For example:

Under a true tiered schedule each dollar is billed at the rate for the tier it falls within. Under a breakpoint schedule the entire balance is billed at the rate corresponding to the highest tier reached. The distinction matters significantly for large accounts and must be clearly defined in the advisory agreement.

Flat-Plus-AUM Hybrid. Combines a fixed planning fee with a lower AUM percentage. Useful for firms that want to be compensated for planning work independently of portfolio size.

Hourly. Charges based on advisor time. Rarely used as the sole billing method for ongoing relationships but common for project-based planning engagements.

Financial Planning Fees. One-time or recurring fees for plan creation and updates, often billed separately from investment management fees.

Performance-Based Fees. Permitted only for "qualified clients" under SEC Rule 205-3 (generally $1.1 million in AUM with the adviser or net worth exceeding $2.2 million). Requires a high-water mark or similar mechanism to prevent double-charging after drawdowns. Rarely used by typical RIAs due to complexity and regulatory constraints.

Family / Household Billing Aggregation. Assets across related accounts (spouses, trusts, custodial accounts, IRAs) are combined for fee-tier determination, then the calculated fee is allocated back to individual accounts. This gives the household the benefit of breakpoint pricing. The aggregation definition (who qualifies as "household") must be documented in the advisory agreement.

2. AUM Valuation for Billing

The accuracy and consistency of AUM valuation directly determines billing accuracy.

Valuation Date Selection. The most common approaches are:

• Quarter-end value: Assets valued as of the last business day of the billing quarter. Simple and widely used.
• Prior quarter-end value: Assets valued as of the end of the preceding quarter. Avoids billing on unrealized gains or losses that occurred during the period just ended. Common for advance billing.
• Period average: The average of daily or month-end values across the billing period. Smooths volatility but is operationally complex.

Market Value vs. Cost Basis. Nearly all advisory agreements specify market value. Cost basis would understate the true value being managed and is almost never used.

Held-Away Assets. Assets the adviser monitors but that are not custodied at the primary custodian (e.g., 401(k) plans, outside brokerage accounts, annuities). Whether these are included in the billable AUM depends on the advisory agreement. If included, obtaining timely and accurate valuations is a persistent operational challenge.

Accrued Income. Bond accrued interest and declared but unpaid dividends may be included or excluded. Most custodian feeds include accrued interest in the total market value, so the default is typically inclusion unless the fee schedule specifies otherwise.

Margin Debit Treatment. If a client uses margin, the question arises whether to bill on gross assets or net equity. The advisory agreement should specify. Most firms bill on net equity (gross market value minus margin balance).

Cash Inclusion / Exclusion. Some agreements exclude cash or money market positions from billable AUM, particularly if the adviser is not actively managing those balances. This is uncommon but must be handled when present.

New Account Proration. Accounts opened mid-period require proration. The standard method is to calculate the fee based on the number of days the account was open relative to the total days in the billing period. Some firms use a simpler approach and bill for the partial quarter only if the account was opened before the midpoint of the period.

3. Billing Cycle Mechanics

Quarterly Billing. The dominant cycle for RIAs. Billing quarters typically align with calendar quarters (Jan-Mar, Apr-Jun, Jul-Sep, Oct-Dec), though some firms use fiscal quarters.

Monthly Billing. Less common for investment management but used for financial planning retainers or firms that want to smooth revenue. Requires more operational overhead.

Annual Billing. Occasionally used for flat-fee or financial-planning-only arrangements. May be billed as a single payment or split into installments.

Advance vs. Arrears Billing.

• Advance (in advance): Fees are billed at the start of the period for services to be rendered. Creates a deferred revenue liability on the firm's balance sheet. Requires refund calculation for accounts terminated mid-period. Most common for RIAs.
• Arrears (in arrears): Fees are billed at the end of the period for services already rendered. Simpler from a revenue-recognition standpoint (revenue is earned when billed) but delays cash collection. Growing in popularity due to its alignment with the service delivery timeline.

Pro-Ration Rules. Events requiring proration include:

• Account openings mid-period
• Account closings or terminations mid-period
• Large contributions (some firms apply a materiality threshold, e.g., only prorate for contributions exceeding $10,000 or 10% of account value)
• Large withdrawals (same materiality threshold logic)
• Transfers between accounts within the same household (should be revenue-neutral)

The standard proration formula is:

Prorated Fee = Full-Period Fee * (Days in Period Account Was Active / Total Days in Period)

Billing Period Alignment. When a firm converts billing cycles (e.g., from quarterly to monthly), a transition period is needed. Clients should not be double-billed or under-billed during the switch. A reconciliation calculation comparing what was billed under the old cycle against what is owed under the new cycle is essential.

4. Fee Calculation Engine

A systematic fee calculation follows these steps:

Step 1: Determine Household Composition. Identify all accounts linked to the billing household. Include all account types per the advisory agreement (individual, joint, IRA, Roth IRA, trust, UGMA/UTMA, entity accounts).

Step 2: Retrieve Account Valuations. Pull market values as of the valuation date from the custodian or portfolio management system. Apply any exclusions (cash exclusion, held-away asset inclusion, margin debit netting).

Step 3: Aggregate Household AUM. Sum the billable market values across all accounts in the household to determine the household-level AUM for tier determination.

Step 4: Apply Fee Schedule. Using the household's assigned fee schedule, calculate the annual fee. For a tiered schedule:

Household AUM: $1,800,000
Tier 1: $500,000 * 1.00% = $5,000
Tier 2: $500,000 * 0.80% = $4,000
Tier 3: $800,000 * 0.60% = $4,800
Annual Fee: $13,800
Effective Rate: 0.767%

Step 5: Convert to Billing Period. Divide the annual fee by the number of billing periods (4 for quarterly, 12 for monthly).

Quarterly Fee: $13,800 / 4 = $3,450

Step 6: Apply Overrides and Adjustments. Check for negotiated rate overrides, minimum fee floors, fee caps, waivers, or credits. Apply in the correct order (typically: calculate standard fee, then apply negotiated rate, then apply minimum, then apply cap, then apply waivers).

Step 7: Allocate to Accounts. Distribute the household fee across individual accounts, typically pro-rata by market value:

Account A ($900,000 / $1,800,000) = 50% * $3,450 = $1,725.00
Account B ($500,000 / $1,800,000) = 27.78% * $3,450 = $958.33
Account C ($400,000 / $1,800,000) = 22.22% * $3,450 = $766.67

Step 8: Apply Proration. For any accounts opened or closed mid-period, prorate the allocated fee.

Step 9: Rounding. Apply consistent rounding rules (typically round to the nearest cent). Ensure rounding differences are allocated to a designated account (usually the largest) so the sum of account-level fees equals the household fee exactly.

Step 10: Generate Billing Output. Produce the custodian debit instruction file or invoice, the billing detail report, and the audit trail record.

Minimum Fee Application. Many firms set a minimum quarterly or annual fee (e.g., $250/quarter). If the calculated fee falls below the minimum, the minimum is charged instead. This should be applied at the household level, not the account level.

Fee Cap Application. Less common but sometimes offered to attract large accounts. A cap ensures the dollar fee does not exceed a maximum regardless of AUM growth.

Negotiated Rate Overrides. Individual clients or households may have rates that differ from the published fee schedule. The billing system must support per-household or per-account rate overrides while maintaining an audit trail of who authorized the deviation and when.

Rounding Rules. Define and document the rounding convention. Typical practice rounds each account fee to the nearest cent. Allocate any remainder (positive or negative) from rounding to the largest account in the household.

5. Collection Methods

Direct Debit from Custodian Account. The most common method for RIAs. The adviser sends fee debit instructions to the custodian (Schwab, Fidelity, Pershing, etc.), and the custodian debits the client's account directly. Requires:

• Written authorization in the advisory agreement or a separate billing authorization form
• Custodian-specific file format (varies by custodian; typically CSV or fixed-width)
• Submission within the custodian's billing window (often the first 10-15 business days of the quarter)
• The custodian sends a statement to the client showing the fee deduction, providing a layer of independent oversight

Invoice Billing. The adviser sends an invoice and the client pays by check, wire, or ACH. More common for institutional clients, financial planning fees, or clients who prefer not to authorize direct debits. Increases accounts receivable management burden.

Split Billing Across Accounts. When a household has multiple accounts, the fee can be debited from each account in proportion to its share of the household AUM (the most common approach) or debited entirely from one designated account.

Billing from Specific Accounts. Some clients designate a specific account for fee payment. Common when clients prefer fees to come from a taxable account (for potential tax deductibility) rather than a retirement account.

Tax-Advantaged Account Billing Considerations. Fees can be debited from IRAs and other tax-advantaged accounts, but there are considerations:

• IRA fee debits are not treated as distributions if the fee is for investment management of the IRA assets
• If the fee covers services beyond the IRA (e.g., financial planning for the household), the debit may be treated as a distribution
• Some practitioners recommend paying fees from taxable accounts when possible because the fee payment from an IRA reduces the tax-advantaged balance, whereas paying from a taxable account may be deductible (subject to limitations)
• ERISA plan accounts have additional rules under DOL guidance

Third-Party Billing. When the adviser bills through a TAMP (Turnkey Asset Management Platform) or sub-advisory arrangement, the TAMP may handle billing and remit the adviser's share. The adviser must reconcile the revenue received against the expected calculation.

6. Billing Exceptions and Adjustments

Fee Waivers. Common categories include:

• Employee and employee-family accounts (full or partial waiver)
• Charitable organization accounts (reduced rate or full waiver)
• Pro bono or scholarship accounts
• Accounts below a size threshold during an initial ramp-up period

All waivers should be documented with authorization and expiration (if applicable).

Negotiated Rates. Large clients or those with longstanding relationships may receive custom rates below the standard schedule. The billing system must store the effective date, the negotiated schedule, and the approving authority.

Legacy Fee Schedules. When a firm updates its published fee schedule, existing clients may be grandfathered on the old schedule. The billing system must support multiple active fee schedules concurrently. Over time, legacy schedules create operational complexity and should be periodically reviewed for consolidation.

Retroactive Adjustments. Occur when an error is discovered after billing has been processed. The adjustment should be applied in the next billing cycle (credit or additional debit) with clear documentation of the original error, the corrected calculation, and the net adjustment.

Billing Disputes. When a client disputes a fee, the process should include:

1. Immediate acknowledgment of the dispute
2. Detailed recalculation and documentation
3. Resolution within a defined timeframe (e.g., 30 days)
4. If the client is correct, issue a credit or refund
5. Maintain a dispute log for compliance review

Refunds for Terminated Accounts. For advance-billed accounts, calculate the unearned portion of the fee from the termination date through the end of the billing period and issue a refund. The advisory agreement should specify the refund methodology.

Refund = Quarterly Fee * (Remaining Days / Total Days in Quarter)

Fee Reversals. Full reversal of a fee debit at the custodian level. Typically used when a billing error is caught within the custodian's reversal window (often same-day or next-day). After the reversal window, the correction must be handled as a retroactive adjustment.

7. Revenue Recognition

GAAP Treatment: Advance Billing. When fees are billed at the start of a quarter, the firm recognizes a liability (deferred revenue or unearned fees) at the billing date. Revenue is then recognized ratably over the service period (the quarter). At the end of the quarter, all deferred revenue for that period has been earned and recognized.

GAAP Treatment: Arrears Billing. Revenue accrues over the service period. At the end of each month within the quarter, the firm recognizes one-third of the estimated quarterly fee as accrued revenue. When the fee is billed and collected at quarter-end, the accrual is reversed and replaced with recognized revenue.

Revenue Per Client Metrics. Key metrics include:

• Average revenue per household
• Average revenue per account
• Revenue per advisor
• Effective fee rate (total fees / total AUM) as a blended measure

Revenue Concentration Analysis. Regulators and business prudence demand awareness of concentration risk. If a single client or small group of clients represents a disproportionate share of revenue, the firm faces business risk. Common thresholds to monitor: no single household should exceed 5-10% of total revenue.

Revenue Forecasting. Forecast advisory revenue using:

• Current AUM multiplied by the blended effective fee rate
• Adjust for expected market appreciation or depreciation
• Adjust for expected net new assets (organic growth) or attrition
• Adjust for known fee schedule changes or renegotiations
• Sensitivity analysis across bull, base, and bear market scenarios

8. Compliance and Disclosure

ADV Part 2A (Brochure) Fee Disclosure. Item 5 of Form ADV Part 2A requires clear disclosure of:

• Fee schedules and how fees are calculated
• Whether fees are negotiable
• Billing frequency and collection method
• Whether fees are billed in advance or arrears
• Refund policy for terminated accounts
• Other costs clients may bear (custodian transaction fees, fund expenses, etc.)

The disclosure must be sufficiently detailed that a client can understand the total cost of the advisory relationship.

Fee-on-Fee Issues. When an adviser charges an AUM-based fee on a portfolio that includes mutual funds or ETFs, the client pays both the advisory fee and the underlying fund expense ratio. This "fee on a fee" must be disclosed. Some advisers offset the fund expenses against the advisory fee or use the lowest-cost share classes available to mitigate this concern.

Total Cost of Ownership Disclosure. Best practice (and increasingly expected by regulators) is to present the client with a comprehensive view of all costs: advisory fees, fund expenses, custodian fees, transaction costs, and any other charges. This aligns with the SEC's guidance on adviser fiduciary duty.

Regulation Best Interest (Reg BI) Cost Considerations. For dual-registrant firms, Reg BI requires disclosure of material fees and costs and their impact on the client's investment. The cost comparison between advisory and brokerage accounts is a key element.

ERISA 408(b)(2) Fee Disclosure. For advisers serving retirement plans, ERISA Section 408(b)(2) requires detailed disclosure of all direct and indirect compensation received in connection with plan services. The disclosure must be provided before the engagement begins and updated within 60 days of any change.

Fee Reasonableness Documentation. Advisers should maintain documentation supporting the reasonableness of their fees. This includes periodic benchmarking against industry surveys (e.g., the annual RIA benchmarking studies from Schwab, Fidelity, or InvestmentNews), documentation of the services provided for the fee, and consideration of the client's total cost.

9. Billing System Architecture

Core Components:

• Fee Schedule Repository. A database of all fee schedules (standard and negotiated), including effective dates, tier structures, and associated metadata. Must support versioning so historical calculations can be recreated.

• Account/Household Master. Links accounts to billing households, assigns fee schedules, stores billing preferences (collection method, billing account designation, proration rules).

• Valuation Engine. Retrieves or calculates account market values as of the billing date. Sources include custodian position files, portfolio management systems, and manual entries for held-away assets.

• Calculation Engine. The core logic that executes the ten-step process described in Section 4. Must handle all fee schedule types, proration, overrides, minimums, caps, and rounding.

• Custodian Debit Instruction Generator. Produces the custodian-specific file format for fee debits. Each custodian (Schwab, Fidelity, Pershing, TD Ameritrade legacy, etc.) has its own format requirements, submission deadlines, and reversal procedures.

• Invoice Generator. For clients billed by invoice, produces statements with fee detail.

Integration Points:

• Portfolio Management System (PMS). The billing system pulls valuations and account structure from the PMS. In some platforms (e.g., Orion, Black Diamond, Tamarac), the billing engine is integrated into the PMS.
• Custodian. Bidirectional: the billing system sends debit instructions to the custodian and receives confirmation (or rejection) files back.
• CRM. Fee schedule assignments and negotiated rates may be managed in the CRM and synchronized to the billing system.
• Accounting System. Billing output feeds revenue entries in the firm's general ledger.

Billing Preview and Approval Workflow.

1. The billing engine runs in preview mode, producing a billing preview report.
2. Operations staff review the preview for anomalies (unusually large fees, negative fees, zero-dollar fees, fees that deviate significantly from the prior period).
3. Exceptions are investigated and resolved.
4. An authorized person approves the billing run.
5. The engine generates the final debit instructions or invoices.
6. Instructions are submitted to custodians.

Audit Trail. Every billing run must produce a complete audit trail including:

• Valuation date and source
• Fee schedule applied (with version identifier)
• Household AUM and per-account AUM
• Step-by-step calculation detail
• Any overrides, waivers, or adjustments applied
• The identity of the person who approved the billing run
• Timestamp of submission to the custodian

Billing Reports. Standard reports include:

• Billing summary by household (fee, effective rate, AUM)
• Billing detail by account
• Period-over-period comparison (fee change from prior quarter)
• Exception report (new accounts, terminated accounts, large variances)
• Revenue summary by advisor, team, or branch
• Accounts receivable aging (for invoice-billed clients)

Worked Examples

Example 1: Quarterly Fee Calculation for a Household with Tiered Pricing

Scenario: The Harrison household has five accounts under a tiered fee schedule. The firm bills quarterly in advance based on prior quarter-end values. The fee schedule is:

Account valuations as of the prior quarter-end (December 31):

Design Considerations:

• The 529 plan is held away at a separate custodian. The advisory agreement specifies it is included in billable AUM for tier determination but fees on the 529 are billed by invoice, not direct debit.
• The household prefers that direct-debit fees come from the taxable joint account, not the IRAs or trust.
• The firm applies rounding to the nearest cent and allocates rounding differences to the largest account.

Analysis:

Step 1 — Aggregate household AUM: $1,200,000 + $650,000 + $480,000 + $850,000 + $120,000 = $3,300,000

Step 2 — Apply tiered schedule:

• Tier 1: $500,000 at 1.00% = $5,000.00
• Tier 2: $500,000 at 0.85% = $4,250.00
• Tier 3: $2,000,000 at 0.65% = $13,000.00
• Tier 4: $300,000 at 0.50% = $1,500.00
• Annual fee: $23,750.00
• Effective rate: $23,750 / $3,300,000 = 0.7197%

Step 3 — Quarterly fee: $23,750.00 / 4 = $5,937.50

Step 4 — Allocate to accounts pro rata by market value:

The raw allocation sums to $5,938.01 due to rounding, which is $0.51 over the $5,937.50 quarterly fee. The rounding adjustment of -$0.51 is applied to the largest account (Harrison Joint), reducing its fee to $2,158.58.

Final billing output:

• Direct debit from Harrison Joint account: $4,521.58 (covering Joint $2,158.58 + IRA Mr. $1,170.01 + IRA Mrs. $863.64 + Trust $1,529.35, with trust fee adjusted by rounding allocation)
• Invoice to Harrison for 529 plan: $215.91

Note: Because the household prefers all direct-debit fees to come from the joint account, the custodian debit instruction is a single debit of $5,721.59 from the joint account. However, the billing detail report still shows the per-account allocation for transparency and performance reporting accuracy.

Example 2: Mid-Quarter Account Events — Transfers, Contributions, and Terminations

Scenario: The Martinez household bills quarterly in advance (Q2: April 1 through June 30, 91 days). At the start of Q2, the household has two accounts:

During Q2, three events occur:

1. On April 20 (day 20 of 91), a $200,000 contribution is made to the taxable account.
2. On May 15 (day 45 of 91), a new Roth IRA is opened with a $50,000 transfer from the taxable account.
3. On June 10 (day 71 of 91), the IRA is terminated and the balance is rolled over to another firm.

Design Considerations:

• The firm's policy is to prorate for contributions over $25,000 and for all account openings and closings.
• Since billing is in advance, the Q2 fee was already debited on April 1. Adjustments will appear on the Q3 billing run.
• Internal transfers (item 2) should be revenue-neutral at the household level.

Analysis:

Event 1 — $200,000 contribution on April 20: Additional billable days: 71 days remaining out of 91 (April 20 through June 30). Additional annual fee on $200,000 at the household's effective rate (1.00% flat in this case): $2,000. Additional quarterly fee: $2,000 / 4 = $500. Prorated additional fee: $500 * (71 / 91) = $390.11. This will be charged as an adjustment on the Q3 billing run.

Event 2 — Roth IRA opened May 15 via internal transfer: The $50,000 moves from the taxable account to the new Roth IRA. Since this is an intra-household transfer, the household AUM does not change and no fee adjustment is needed. The per-account allocation will be updated for the new account going forward, but the household-level fee remains the same.

Event 3 — IRA terminated June 10: The IRA was billed $500 for the full quarter. Days active: 71 out of 91 (April 1 through June 10). Days unused: 20 out of 91. Refund: $500 * (20 / 91) = $109.89. This refund is applied as a credit on the Q3 billing run.

Net Q3 adjustment for the Martinez household:

• Additional charge for contribution: +$390.11
• Refund for early termination: -$109.89
• Net adjustment: +$280.22 added to the Q3 fee

The billing detail report for Q3 will show the standard Q3 fee plus a line item for the Q2 adjustment with a reference to each underlying event.

Example 3: Billing System Migration from Spreadsheet to Automated Platform

Scenario: A 15-advisor RIA managing $2.1 billion across 1,800 households currently calculates fees using a series of Excel workbooks maintained by two operations staff. The firm is migrating to an integrated billing module within their portfolio management system. The spreadsheet system has worked for years but is error-prone, poorly documented, and dependent on key personnel.

Design Considerations:

• The firm has 14 distinct fee schedules (including 6 legacy schedules that apply to fewer than 50 households each).
• Approximately 120 households have negotiated rates that differ from the standard schedule.
• The firm bills quarterly in advance, debiting from custodian accounts at Schwab and Fidelity.
• The migration must not disrupt the next quarterly billing cycle.

Analysis:

Phase 1 — Data Extraction and Documentation (Weeks 1-3):

• Export all fee schedules from the existing spreadsheets into a structured format (schedule name, tier breakpoints, rates, effective date).
• Document every negotiated rate override with the associated household, effective date, and authorizing advisor.
• Catalog all billing exceptions: waivers, caps, minimum overrides, split-billing arrangements, invoice-billed accounts.
• Extract two years of historical billing data (household, account, AUM, fee charged, period) for parallel-run comparison.

Phase 2 — System Configuration (Weeks 3-6):

• Configure all 14 fee schedules in the new billing module with correct tier structures and effective dates.
• Enter negotiated rate overrides per household.
• Configure billing preferences per household: collection method, billing account designation, proration rules.
• Set up custodian debit file formats for Schwab and Fidelity.
• Configure the approval workflow (preview, review, approve, submit).

Phase 3 — Parallel Run (Weeks 6-9, coinciding with one billing cycle):

• Run the new system in parallel with the spreadsheet process for one full quarterly cycle.
• Compare results at the household level. Accept a tolerance of $0.01 per household for rounding differences.
• Investigate and resolve every variance exceeding the tolerance.
• Common variance sources: different rounding methods, different day-count conventions for proration, fee schedule data entry errors, missing negotiated rate overrides.

Phase 4 — Cutover (Week 10):

• After parallel-run sign-off, the new system becomes the system of record.
• The spreadsheet process is retained as a reference but is no longer used for production billing.
• First live billing cycle is run with enhanced review (every household is spot-checked, not just exceptions).

Phase 5 — Post-Migration Monitoring (Weeks 10-22, two billing cycles):

• Heightened review of billing output for two additional cycles.
• Monitor client inquiries or complaints related to fee amounts.
• Validate that custodian debit files are accepted without error.
• Confirm revenue recognition entries in the accounting system match prior methodology.

Key success metrics:

• Zero missed billing cycles during migration.
• Variance rate below 0.5% of households in the first live cycle.
• Reduction in billing processing time from approximately 40 person-hours per quarter to under 8 person-hours.
• Elimination of single-point-of-failure key-person risk.

Common Pitfalls

• Confusing tiered and breakpoint pricing. A tiered schedule charges each dollar at the rate for its tier. A breakpoint schedule charges the entire balance at the rate for the highest tier reached. Mixing these up leads to significant billing errors, especially for large accounts.
• Failing to prorate for mid-period events. Not adjusting fees for material contributions, withdrawals, or account openings/closings results in overbilling or underbilling and invites client complaints.
• Ignoring rounding allocation. When per-account fees are rounded independently, the sum may not equal the household fee. Without a systematic rounding allocation, small discrepancies accumulate and create reconciliation headaches.
• Billing retirement accounts for non-retirement services. Debiting an IRA for advisory fees that cover financial planning or services unrelated to the IRA assets can trigger a taxable distribution. Always confirm that fees debited from tax-advantaged accounts correspond to services for those accounts.
• Neglecting to update negotiated rates. When a fee schedule is updated but negotiated rate clients are forgotten, those clients may continue paying outdated rates indefinitely. Maintain a review cadence for all non-standard arrangements.
• Inadequate disclosure of fee-on-fee costs. Failing to disclose that clients pay both the advisory fee and underlying fund expenses is a recurring SEC examination finding. Ensure ADV Part 2A and client communications address total cost clearly.
• Missing the custodian billing window. Each custodian has a defined window for accepting fee debit instructions. Missing the window delays fee collection by an entire quarter and disrupts cash flow.
• Not reconciling custodian confirmations. After submitting debit instructions, the custodian returns a confirmation file indicating which debits were processed and which were rejected (insufficient funds, account closed, etc.). Failing to review this file means rejected debits go uncollected.
• Advance-billing refund errors on termination. When an advance-billed account terminates mid-quarter, the firm owes a prorated refund. Incorrect day-count calculations or failing to issue the refund entirely creates compliance risk and client ill will.
• Overcomplicating household definitions. Overly broad household aggregation (e.g., including extended family members who are not part of the advisory relationship) can inflate tier benefits. Overly narrow definitions deprive clients of legitimate aggregation. The definition must match the advisory agreement.
• Lack of billing audit trail. Without a detailed record of every calculation input and output, the firm cannot defend its billing in the event of a client dispute or regulatory examination.
• Revenue recognition timing errors. Recognizing advance-billed fees as revenue immediately rather than deferring and recognizing ratably overstates revenue in the billing period and understates it in subsequent periods.

Cross-References

• fee-disclosure — Detailed requirements for fee disclosure in client-facing documents and regulatory filings.
• portfolio-management-systems — Integration between billing engines and PMS platforms for valuation and account data.
• advisor-dashboards — Revenue metrics, billing status, and fee analytics displayed on advisor-facing dashboards.
• client-reporting-delivery — Inclusion of fee summaries and performance-net-of-fee figures in client reports.
• investment-policy — Fee schedule terms as specified in the investment policy statement or advisory agreement.
• reg-bi — Regulation Best Interest cost disclosure obligations for dual-registrant firms.
• fiduciary-standards — Fiduciary duty to charge reasonable fees and act in the client's best interest regarding cost.
• tax-efficiency — Tax implications of fee payment source (taxable vs. tax-advantaged accounts) and deductibility considerations.
• performance-reporting — Gross-of-fee vs. net-of-fee performance calculation and the role of accurate fee data.