Fee and expense practices of private fund advisers remain in the SEC’s crosshairs. See “SEC Division Heads Enumerate OCIE Priorities, Including Cybersecurity, Fees, Bad Actors and Never-Before Examined Hedge Fund Managers (Part One of Two)” (Apr. 28, 2016). The SEC recently brought suit in Connecticut against a registered investment adviser, alleging improper transfer of client assets into new mutual funds, thereby increasing client advisory fees without changing the clients’ investment strategy. The adviser failed to disclose the alleged conflict of interest to its clients. The SEC seeks an injunction, disgorgement and civil penalties. This article summarizes the facts giving rise to the action and the SEC’s civil complaint. For more on enforcement actions involving fee disclosures and practices, see “Blackstone Settles SEC Charges Over Undisclosed Fee Practices” (Oct. 22, 2015); and “SEC Enforcement Action Involving ‘Broken Deal’ Expenses Emphasizes the Importance of Proper Allocation and Disclosure” (Jul. 9, 2015).