Agent Crew
6 agents deployed
Fee Billing Reconciler
Validate FeesValidates fee schedules against custodian charges. Flags overcharges and schedule mismatches across all accounts.
SchwabOrionQuarterly
Run
Cash Availability Checker
Validate FeesIdentifies accounts with insufficient cash before billing. Generates MMF liquidation trade files automatically.
SchwabDaily 6AM
Run
IPS Drift Detector
Monitor DriftFlags portfolios outside IPS target allocation bands. Compares current holdings vs signed investment policy.
OrionDaily 6AM
Run
Form ADV Auditor
Review DocsCross-checks Part 1 vs Part 2 for disclosure discrepancies. Compares services, fees, client types across filings.
SEC 275.204-3On-demand
Run
Marketing Content Review
Review DocsScans marketing materials against FINRA 2210. Checks disclosures, testimonials, performance claims.
FINRA 2210Email trigger
Run
Client Onboarding Checker
OnboardVerifies all required documents for new clients. Checks suitability, advisory agreement, ID, W-9.
WealthboxCRM event
Run
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Run Complete: Fee Billing Reconciler
Q2 2026 · 2,000 accounts scanned · 47 seconds
1,997
Passed
3
Exceptions
$4,200
Total Variance
100%
Coverage
Analysis
The largest exception is Park 401k (+$3,700) — the fee schedule was not updated after the account was restructured on Apr 12. The client is being charged at the old rate (1.80% annual) instead of the post-restructure rate (0.80% on first $500K). This requires immediate correction and a client refund for the overcharged quarter.
Smith IRA (+$200) is a rounding difference at the tiered schedule boundary — within tolerance for auto-approval. Jones Trust (−$300) is a timing difference from custodian billing lag — will self-correct next cycle.
Recommended Actions
1.Update Park 401k fee schedule in Orion to reflect post-restructure rate (0.80%)
2.Process refund of $3,700 to Park 401k for Q2 overcharge
3.Auto-approve Smith IRA ($200 rounding) — within firm threshold
4.No action on Jones Trust — custodian lag, self-corrects next cycle
Audit trail attached · Sources: Schwab fee report + Orion schedules (v3.2) · Exam-ready evidence
FEE_SCHEDULE_THRESHOLD
Park_401k.fee_rate ≤ advisory_agreement.max_rate (0.0080)
—
FEE_MATCHES_CUSTODIAN
orion.fee_charged = schwab.fee_debited
—
AGREEMENT_IS_CURRENT
advisory_agreement.signed_date within 365d
—
RESTRUCTURE_FEE_UPDATE
if account.restructured → fee_schedule.updated_after(restructure_date)
—
BILLING_CYCLE_CORRECT
billing.frequency = agreement.billing_frequency
—
CASH_SUFFICIENT_FOR_DEBIT
account.cash_balance ≥ quarterly_fee_amount
—
6
Rules Checked
5 passed
1 flagged
←
Rule Failed: RESTRUCTURE_FEE_UPDATE
Park 401k · Evaluated Jun 15, 6:00 AM
Rule Evaluation Detail
Rule:fee_schedule.updated_after(restructure_date)
Account:Park 401k
Restructured:Apr 12, 2026
Fee last updated:Never — still using pre-restructure rate
Expected rate:0.80% on first $500K → $800/qtr
Actual rate charged:1.80% annual → $4,500/qtr
Overcharge:$3,700
Determination
The fee schedule in Orion was not updated after the account restructure on Apr 12. The client is being billed at the old rate (1.80%) instead of the correct post-restructure rate (0.80% tiered). This results in an overcharge of $3,700 for Q2 2026. The advisory agreement (signed Apr 12) specifies the new rate — Orion is out of sync.
Recommended Actions
1.Update fee schedule in Orion to 0.80% (per advisory agreement Apr 12)
2.Process refund of $3,700 to Park 401k
3.Flag for CFO review (overcharge exceeds $500 threshold)
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