How to check flat fee and retainer billing errors

A flat fee removes asset multiplication, not reconciliation. Amounts, service dates, cadence, credits and termination terms can drift between signed terms and recurring settings.

Worked example: overlapping invoices

Assume $300 per month with no additional onboarding fee. Twelve monthly charges total $3,600. An additional $3,600 annual invoice for the same obligation and period would be a potential duplicate. Confirm the service scope and dates before reaching that conclusion.

For a hypothetical 30 day month and 10 eligible days, a contract allowing daily proration gives $100. Do not assume proration if the terms specify something else.

Review checklist

1. Match recurring amount and frequency to signed terms.
2. Compare activation dates with service commencement.
3. Identify paused, waived and terminated periods.
4. Search both manual and recurring invoices for overlap.
5. Check whether a planning retainer offsets an AUM charge or is separately payable.
6. Verify anniversary increases and minimums against supporting terms.
7. Reconcile actual payments, rejections, credits and refunds separately.

The 2018 SEC staff alert discussed frequency discrepancies, incorrect rates, duplicate billing and omitted rebates. SEC OCIE advisory fee and expense risk alert (2018) These examples are operational illustrations, not a statement that one rule governs every retainer.

FAQ

Related guides

• Quarterly advisory fees: advance versus arrears
• refund overbilled advisory clients.

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