It is axiomatic that an investment adviser must always act in the best interests of its clients, including as their circumstances change. The SEC expects advisers to adopt policies and procedures reasonably designed to satisfy that obligation. The SEC’s recently settled enforcement proceeding against an investment adviser is a reminder that advisers must periodically review their clients’ accounts to ensure that they are not overcharging the clients – and have policies and procedures for doing so. The adviser offered wrap fee accounts to clients but, contrary to its disclosures, allegedly failed to review those accounts periodically to ensure that they remained suitable for the clients. Moreover, certain wrap fee clients also incurred transaction costs that should have been included in the wrap fee. This article outlines the alleged compliance failures and the terms of the SEC settlement order. See “Pair of Risk Alerts Focuses on Issues Associated With Cross Trades, Principal Transactions and Wrap Fees” (Aug. 19, 2021); and “Pay to Play, Revenue Sharing and Wrap Fees Remain on the SEC’s Radar” (Apr. 20, 2017).