The SEC charged the registered investment adviser, Transamerica Retirement Advisors, LLC, for breaching its fiduciary duty to certain of its advisory clients by failing to disclose conflicts of interest related to its incentive compensation practices. The adviser offered investment education and managed account services to participants of approximately 9,400 employer-sponsored retirement plans with approximately 1.5 million participants in connection with recordkeeping services provided to these plans by its parent company. The firm allegedly paid incentive compensation to its retirement planning consultants for referring employer plan participants to its investment advisor representatives to consider whether to rollover plan assets into advisory accounts, resulting in additional revenue of approximately $12 million for the firm during the relevant period. In settling the case, the firm agreed to a $2.9 million civil penalty to be distributed to affected investors. This case does not involve private funds but rather focuses on retail investors. However, it does highlight the SEC’s ongoing focus on disclosure of conflicts related to compensation practices and reiterates that disclosing that a practice may occur when it actually does occur is not sufficient.