Match custodian fee debits to your billing system

Use actual debit records, not only the file submitted for collection. Submitted charges can be rejected, partially paid or reversed. Keep the fee calculation test separate from the collection comparison.

Prepare the match

Use stable account identifiers, billing run references, service start and end, expected amount, actual transaction date, signed amount and reversal references. Preserve raw transaction IDs. Record authorized paying account mappings instead of relying on matching amounts alone.

Worked example: a reversal

Billing output is $2,875. Custodian records contain a $2,875 debit, its full reversal and a replacement $2,875 debit. Net collection is $2,875, not $5,750. Verify the reversal actually belongs to the original before netting it.

Two unreversed debits for one authorized charge suggest a possible duplicate. A $2,500 net debit leaves $375 to investigate, including any later collection.

Exception categories

1. Calculation differs from the agreement.
2. Approved amount differs from collection.
3. Posting falls outside the report window.
4. Charge used an authorized paying account.
5. Duplicate or reversal needs investigation.
6. Missing data prevents a reliable match.

Set an explicit posting window and carry unresolved items forward. Do not force matches to make totals balance. Validate export coverage.

The 2021 staff alert described duplicate billing and valuation errors involving electronic feed timing. SEC Division of Examinations fee calculation observations (2021)

FAQ

Related guides

• RIA fee billing reconciliation checklist
• household aggregation breakpoints.

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Start a free audit or see sample findings. FeeAlign provides operational reconciliation, not investment, legal, tax or compliance advice. Your CCO and counsel decide how to apply the findings.