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During inspections, the examination staff review an adviser's filings with the Commission5 and other materials provided to clients to ensure that the adviser's disclosures are accurate, timely, and do not omit material information. Examples of failures to disclose material information to clients would include:
- An adviser fails to disclose all fees that a client would pay in connection with the advisory contract, including how fees are charged, and whether fees are negotiable;6
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