How to document advisory fee overbilling and refunds

Start by proving the difference. A debit above a draft estimate is not necessarily overbilling. Updating the next rate does not itself resolve a past overcharge. Preserve evidence and involve the CCO and counsel when assessing client impact.

Worked example: excess charge

Expected quarterly fee is $2,875 and actual net charge is $3,000. The excess is $125. Four independently checked quarters with identical relevant inputs would total $500. Do not extrapolate across a year without checking each period's balance, schedule, credits and prior corrections.

Separate prepaid refunds

For a hypothetical $2,500 prepaid fee covering 90 days, with 30 unused days, a contract using unused days divided by period days gives $833.33. Verify date counting and termination terms. This is not a universal refund formula.

Resolution record

1. Preserve source exports and applicable terms by period.
2. Establish the affected population, including closed accounts.
3. Recalculate expected fees and net charges.
4. Check previous credits, reversals and refunds.
5. Have the CCO and counsel assess scope, any additional amounts, communications and reporting obligations.
6. Approve the correction method and verify that payment or a permitted credit occurred.
7. Fix the cause and test the next billing run.

The 2021 alert described inconsistent or delayed refunds of unearned prepaid fees where agreements or disclosures required them. SEC Division of Examinations fee calculation observations (2021) This guide does not establish a universal deadline or say repayment alone resolves every obligation.

## Home, navigation and discovery

Nav and footer label: Guides, pointing to /guides. Home heading: Check the fee calculations behind the debit. Home body: Practical examples for tiers, household breakpoints, quarterly billing and custodian reconciliation. Start with the checklist or work through a fee calculation. Home links: checklist, tiered guide, household guide and Browse all fee billing guides pointing to /guides. Add all eleven canonical routes to sitemap.xml and llms.txt without losing current entries. Use actual modification dates, not invented freshness.

## Optional calculator brief

Not implemented. /tools/fee-calculator can show marginal tier contributions, total annual fee, effective blended rate and selected period fee. Explicitly distinguish one all assets breakpoint method. Validate zero assets, negative and nonfinite values, tier ordering and empty rates. Avoid dividing by zero; preserve adequate precision and round at the specified step. Test $1.5 million at 1% on the first million and 0.75% thereafter: $13,750 annual, $3,437.50 for one equal quarter. No uploads, credentials or external requests. Label outputs illustrative and subordinate to the agreement.

## Release acceptance checklist

1. Read workspace status, preserve unrelated changes and avoid committing unrelated staged edits.
2. Add the ten guides and index with unique titles, descriptions, H1s, canonicals and visible FAQs.
3. Link related guides, /start, /sample-findings and verified relevant existing state pages.
4. Add navigation, footer and home discovery; update sitemap and llms.
5. Verify build, direct URL 200s, actual rendered content rather than a soft 404, metadata, noindex absence, mobile layout, internal links and structured data validity.
6. Verify unchanged pricing, forms, Stripe and SITE_MODE.
7. Record full commit and deployment identifiers.
8. Read the complete existing public IndexNow key from its established public verification file, not from the prefix in the brief. Submit only live verified canonical URLs to documented endpoints if authorized. Record status and response. A 200 means acceptance, not indexing; a 202 means pending key validation. Do not claim Google indexing without evidence.

FAQ

Related guides

• SEC advisory fee billing findings: an operations checklist
• quarterly billing advance vs arrears.

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