The six part “improper practices” BillFin article series continues this month moving onto risk number two: Billing Fees in Advance or with Improper Frequency. Since the US Securities and Exchange Commission issued a risk alert on advisory fee billing and compliance back in April, Redi2 is committed to resolving these worries by explaining how BillFin handles such concerns. Issue: Advisors’ Billing Practices Inconsistent with their ADV or Advisory Agreement OCIE staff found that many advisors’ claim to bill on a quarterly basis; however, they actually ran their advisory fees on a monthly basis. They also found advisors’ billing in advance when their agreement states in arrears. BillFin Solution: Flexible Billing for Consistency While BillFin will not review your ADV before you bill, it will allow the flexibility advisors need to properly bill and maintain accuracy with their ADV and advisor agreement. Advisors can bill monthly or quarterly, forward and arrears, with override settings available for clients with different billing arrangements.
Back in April, the US Securities and Exchange Commission issued a risk alert on advisory fee billing and compliance. Of the six most frequent compliance issues they outlined, BillFin can help ensure the top five are not concerns for your fee billing (see our June article). Let’s start with issue number one: Fee Billing Based on Incorrect Account Valuations. BillFin is extremely flexible and simple to use. The workflow is as simple as calculating fees, exporting your invoices, and then exporting your debit files. Since the first step is critically important, you will need your management fees to be correct and for that, the account valuations must be correct.
On April 12th, the Office of Compliance Inspections and Examinations released a 4-page risk alert detailing the most frequent issues with advisor fees and expense compliance. We encourage you to review the alert on their website provided below. We also want to assure you BillFin is the solution to the concerns they raise. Please read Redi2’s statement below the link for some peace of mind regarding your fee billing practices when using BillFin. The major concern expressed in the risk alert is that advisors are simply not billing in accordance with the terms in their Form ADV and other materials that are provided to their clients. The most frequent compliance issues they list are outlined below.