Independent fee verification · registered investment advisers
Each quarter we recompute every advisory fee against your own agreements and fee schedules, and send back the exceptions in dollars, in both directions, with a testing record for your compliance file. Nothing with a client name on it ever leaves your firm.
01 · What you get
Arithmetic verification of what you billed against what you wrote. Not an opinion, not an audit: the numbers, traced to the page.
Every account where the fee billed differs from the fee your own schedule produces. Over and under. Each one names the rule it broke and the page the rule came from: tier, breakpoint, household, minimum, discount, proration, termination.
One page in the format examiners ask for: population tested, method, tolerance, findings by type, totals over and under, who reviewed. Ready to attach to the annual review under Rule 206(4)-7.
Tiers, breakpoints, household rules, minimums, discounts and prorations, extracted from your agreements and kept current. Amend an agreement and the next quarter picks it up. Yours to keep.
Our standard
A verified fee is one you can follow back to the agreement, the schedule, the page. Our AI reads the documents into rules, deterministic code recomputes every account, and a person reviews every exception before it reaches you.
02 · How it works
Your billing export with account IDs only, your fee schedules, your advisory agreement templates and ADV Part 2A. An NDA first if you want one.
Every tier, breakpoint, household rule, minimum, discount and proration becomes a rule in a table, with the page it came from. You confirm the table once.
Deterministic code, not a model, computes the expected fee for every account and compares it with what was billed. A person reviews each exception.
Within 48 hours for the sample, then every quarter after your billing run. Excel and PDF, plus the testing record for your file.
03 · Why now
The SEC's Division of Examinations has written about advisory-fee errors three times in five years. The findings are plain arithmetic: wrong rates, wrong values, missed discounts, double billing.
Fee-calculation deficiencies found "during most" of about 130 adviser examinations in a national sweep.
SEC risk alert on advisory fee calculationsRisk alert lists incorrect rates, inaccurate account values, missed discounts and duplicative billing.
SEC risk alert on economic conflicts of interestAnnual compliance reviews cited for fees "calculated on a different basis than disclosed" and missing documentation.
SEC risk alert on annual compliance reviewsExamination priorities name fee and expense calculations, with a focus on advisers never examined before.
SEC Division of Examinations priorities04 · Price
Fixed before we start. No per-exception fees, no success fees. Cancel any quarter. The sample is free because it is the best way to show you what you would be paying for.
| Item | What it covers | USD |
|---|---|---|
| Sample | One quarter, anonymised export, exceptions back within 48 hours | 0 |
| Setup | Rule library from your agreements and schedules, export mapping, first full recompute | 1,500 |
| Quarterly · up to 300 accounts | Recompute, exceptions in Excel and PDF, testing record | 750 |
| Quarterly · up to 1,000 accounts | Same | 1,200 |
| Quarterly · up to 3,000 accounts | Same | 2,000 |
| Larger firms | Quoted on the export | — |
05 · Data
The recompute needs numbers and codes, not people. Your export is anonymised before it leaves your firm, so there is no nonpublic personal information to safeguard on our side.
What we need
What we never see
06 · Who
Menlo is named for Edison's laboratory at Menlo Park, New Jersey, the first place that turned invention into a method: build, test, set aside what does not hold, keep what does. The grid in our mark is every path tried. The one yellow dot is the figure that holds.
Our last engagement replaced a regulated lender's investor-notes system. Interest, payment and withholding schedules were recomputed and matched to the cent against the old vendor's full export before cut-over. Fee Check is that method, applied to advisory billing, every quarter.
07 · Contact
Reply within one business day. Exceptions back within 48 hours of receiving the export. If we find nothing, you still get the testing record.
