The SEC Division of Examinations recently issued a risk alert on its observations regarding investment advisers’ fee calculations. Although the alert focuses on advisers’ practices with respect to retail clients, it contains important reminders for private fund advisers, including the need for clear policies, procedures and controls governing fee and billing practices, as well as robust disclosures. This article analyzes the alert, with commentary from Victoria Hogan, president of NorthPoint Compliance and former SEC examiner; and Michael J. Osnato, Jr., partner at Simpson Thacher and former Chief of the Complex Financial Instruments Unit of the SEC Division of Enforcement. See “Practical Lessons From OCIE’s Risk Alert on Compliance Issues for Private Fund Managers (Part Two of Two)” (Dec. 3, 2020).