On June 9, the SEC’s Division of Examinations issued a risk alert summarizing observations from examinations of investment advisers’ obligations related to economic conflicts of interest. The alert identifies examination observations across five categories: (i) conflicts of interest that were not adequately disclosed to clients; (ii) conflicts associated with other revenue opportunities, including advisers that did not disclose that lower-cost share classes of the same mutual funds were available; (iii) compensation-related misstatements or omissions in Form ADV brochures; (iv) fees deviating from advisory agreements and disclosures, such as prorating fees in situations not addressed by agreements, charging asset-based fees on excluded holdings, and assessing fees for services not provided; and (v) compliance programs that lacked controls to monitor for accurate fee calculations and rebates or failed to address all applicable billing arrangements. The division encouraged advisers to regularly review and refine their billing policies, procedures, and practices to ensure accuracy and consistency with disclosures and agreements.