On June 9, 2026, the SEC’s Division of Examinations issued a Risk Alert highlighting that investment advisers must fully and fairly disclose all economic conflicts of interest, particularly those arising from compensation, revenue sharing, and product recommendations. The alert highlighted how examinations continue to reveal deficiencies in these areas, including undisclosed or misleading disclosures about revenue arrangements, inconsistent fee billing practices, and compliance programs that failed to address all types of billing arrangements or monitor fee accuracy. 

CCOs should ensure that disclosures are clear, complete, and consistent across all documents and ensure that compliance programs are robust enough to identify, monitor, and address economic conflicts and fee-related issues. Regular reviews and updates to policies, procedures, and client communications are essential to meet fiduciary obligations and regulatory expectations. 

While the deficiencies addressed in this risk alert are most relevant for wealth managers, private fund managers should focus on cash management and treasury arrangements and other types of compensation that are applicable to their business for potential conflicts of interest.