RIA fee billing reconciliation checklist

An invoice that matches a debit proves collection, not correct calculation. Follow the charge from agreed terms through independent calculation to the actual deduction.

Before billing

1. Save current agreements, amendments and schedule versions.
2. Export the account population, including opened and terminated accounts.
3. Record valuation dates, service periods, exclusions and household membership.
4. List overrides, minimums, credits and relevant flows.
5. Preserve original exports unchanged. Use masked identifiers when sharing outside the firm.

Recalculate and compare

Apply the agreed asset basis, rates, household rules and period fraction. Test changed accounts and tier boundaries. Label variance direction explicitly and document rounding instead of silently ignoring small differences.

Worked example: two kinds of difference

Account A: expected $2,875; billing output $3,000; actual debit $3,000. The $125 difference suggests a calculation issue.

Account B: expected and billing output $2,875; actual debits $2,500. The $375 difference may be collection, timing or another exception. Do not call it underbilling until investigated.

After collection

Identify rejected charges, reversals and duplicates. Sum allocations back to household totals. Assign unresolved items an owner, evidence and status. Close them only when the result is supported.

The 2021 SEC staff alert described rate, tier, householding and valuation errors. This is a proposed operations workflow, not a prescribed regulatory standard. SEC Division of Examinations fee calculation observations (2021)

FAQ

Related guides

• SEC advisory fee billing findings: an operations checklist
• custodian billing system tie out.

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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.