“Many [SEC] actions center on disclosure and conflicts of interest, including advisors misallocating expenses to funds.”

SEC Chair Mary Jo White, “Five Years On: Regulation of Private Fund Advisors after Dodd-Frank,” 2015

The SEC “maintain[s] a focus on fees and expenses.”

SEC Office of Compliance, Inspections, and Examinations “Examination Priorities,” 2016

$2.9M

Average Misallocation Penalty

The SEC is focused on expense allocation.

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