The SEC settled charges against two Wells Fargo registered investment advisers and against Merrill Lynch for failures relating to the firms’ cash sweep programs. The firms agreed to settle the SEC’s charges and pay $60 million in total civil penalties. These advisers only offered an affiliated cash sweep option for most advisory clients and received a significant financial benefit from advisory client cash in connection with such programs. Private fund managers are generally not affiliated with banks that structure and offer sweep programs as was the case in these enforcement actions. However, they may be responsible for selecting sweep accounts and/or may utilize treasury management products or solutions in connection with managing cash balances and diversifying such balances among multiple money market funds. Such firms should ensure they have adequate policies and procedures to ensure they are acting int he best interest of clients and disclosing any economic benefic received by the firm or an affiliate in connection with such programs.