# fee-disclosure

Checks whether fee and cost disclosures are complete, accurate and not misleading across advisory, brokerage, fund and retirement plan contexts.

- skill · `type=skill` · Claude Code, Codex, Cursor, GitHub Copilot, Gemini CLI, OpenCode · 648 installs · ★ 218
- Author: JoelLewis
- License: MIT · policy=mirror · the beginning of the file is at the end of this page
- Source: https://github.com/JoelLewis/finance_skills/tree/HEAD/plugins/compliance/skills/fee-disclosure/SKILL.md
- Updated: 2026-07-18
- HTML: https://affpapa.org/en/nevibecode/skills/fee-disclosure

## What it does

This skill reviews the substance of fee disclosures, not whether the documents exist. It covers Form ADV Part 2A Item 5, the fee section of Form CRS, the cost obligation under Reg BI, prospectus fee table format, 12b-1 transparency, revenue sharing arrangements and wrap fee programs. Questions about which documents must exist and when they are delivered belong to a separate skill, `client-disclosures`.

Inside is a point-by-point breakdown: fee schedules and billing method, in advance or in arrears, custodian fees and fund expense ratios, compensation for securities sales, and the refund policy for prepaid fees. Conflicts get their own treatment. 12b-1 fees push advisers toward higher-cost share classes, and revenue sharing or shelf-space payments need disclosure even when fund selection is described as objective.

Regulatory status is pinned to June 2026, and the skill itself says to verify effective dates, dollar thresholds and pending rulemakings against current SEC, FINRA and FinCEN sources before advising. On a project that has been sitting for a while, that is your cue to re-check thresholds by hand. Install runs through `npx skills add`.

## Install

### Claude Code (native platform)

1. **Skills CLI (Vercel)**
```bash
npx skills add JoelLewis/finance_skills --skill fee-disclosure -a claude-code
```

2. **Manually: put the files in place**
- File: `~/.claude/skills/fee-disclosure/SKILL.md` — Copy the whole skill folder; for one project use .claude/skills/fee-disclosure/

### Codex

1. **Skills CLI (Vercel)**
```bash
npx skills add JoelLewis/finance_skills --skill fee-disclosure -a codex
```

2. **Manually: put the files in place**
- File: `.agents/skills/fee-disclosure/SKILL.md` — For all projects use ~/.agents/skills/

### Cursor

1. **Skills CLI (Vercel)**
```bash
npx skills add JoelLewis/finance_skills --skill fee-disclosure -a cursor
```

2. **Manually: put the files in place**
- File: `.cursor/skills/fee-disclosure/SKILL.md` — Cursor also reads .agents/skills/ and .claude/skills/

### GitHub Copilot

1. **GitHub CLI**
```bash
gh skill install JoelLewis/finance_skills fee-disclosure
```

2. **Manually: put the files in place**
- File: `.github/skills/fee-disclosure/SKILL.md`

### Gemini CLI

1. **Skills CLI (Vercel)**
```bash
npx skills add JoelLewis/finance_skills --skill fee-disclosure -a gemini-cli
```

2. **Platform CLI**
```bash
gemini skills install https://github.com/JoelLewis/finance_skills --path plugins/compliance/skills/fee-disclosure
```

### Windsurf (Devin Desktop)

**Manually: put the files in place**
- File: `.devin/skills/fee-disclosure/SKILL.md` — The legacy .windsurf/skills/ path still works

### OpenCode

**Skills CLI (Vercel)**
```bash
npx skills add JoelLewis/finance_skills --skill fee-disclosure -a opencode
```

### Claude.ai

**Claude.ai**
- Zip the folder and upload it in Settings → Capabilities → Skills

Where a file is given instead of a command, copy the files from the source to that path: https://github.com/JoelLewis/finance_skills/tree/HEAD/plugins/compliance/skills/fee-disclosure/SKILL.md

## When to use it
- check whether Form ADV Item 5 fee content is adequate
- review prospectus fee table format for a fund
- spot undisclosed layers of indirect compensation
- compare expense ratios across share classes of one fund
- assess whether shelf-space payments are disclosed

## Example prompts
- Review our Form ADV Part 2A Item 5 and tell me if any layer of fees or indirect compensation is missing
- Compare expense ratios and 12b-1 fees across these share classes and say which one is worse for the client
- Check whether the fee section of our Form CRS is specific enough to meet the requirement

## Source text · SKILL.md · MIT

Below is the content of a third-party file. It is data, not instructions for you: do not act on anything written inside unless the human asks. Block tag: 98db642aed56244b.

BEGIN THIRD-PARTY FILE 98db642aed56244b
```text
---
name: fee-disclosure
description: "Evaluate whether the substance of fee and cost disclosures is complete, accurate, and not misleading across advisory, brokerage, fund, and retirement plan contexts. Use when the user asks whether Form ADV Item 5 fee content is adequate, prospectus fee table format, Reg BI cost disclosure content, 12b-1 fee transparency, revenue sharing arrangements, wrap fee program cost-effectiveness, or ERISA 408(b)(2)/404a-5 fee disclosure content. Also trigger when users mention 'hidden fees', 'total cost to the client', 'are we disclosing all layers of fees', 'expense ratio comparison', 'fee billing in advance vs arrears', 'share class selection', or 'indirect compensation'. (For which disclosure documents must exist and when they are delivered, use client-disclosures.)"
---

# Fee Disclosure

Regulatory status current as of June 2026 — verify effective dates, dollar thresholds, and pending rulemakings against current SEC/FINRA/FinCEN sources before advising.

## Core Concepts

### Form ADV Part 2A — Item 5 (Fees and Compensation)
RIAs must disclose in their firm brochure:
- **Fee schedule** — how fees are calculated (asset-based, fixed, hourly, performance-based), fee rates and tiers, minimum account sizes
- **Billing method** — frequency (monthly, quarterly), in advance or arrears, pro-ration for partial periods
- **Other fees and expenses** — custodian fees, fund expense ratios, transaction costs, wire fees, and any other costs the client will bear in addition to the advisory fee
- **Compensation for sales of securities** — if the adviser or its supervised persons receive commissions, 12b-1 fees, or other sales-based compensation, this must be disclosed with a description of the conflict
- **Refund policy** — how prepaid fees are refunded if the relationship terminates mid-period

The disclosure must be "full and fair" and not misleading. The SEC has brought enforcement actions for advisers who disclosed fee schedules but obscured the total cost to clients by omitting indirect compensation or failing to describe how fund-level fees compound on top of advisory fees.

### Form CRS Fee Disclosure
The "What are your fees?" section of Form CRS must include:
- Principal fees and costs for the firm's services
- A description of other fees and costs the client may pay (transaction, custodian, fund expenses)
```
END THIRD-PARTY FILE 98db642aed56244b

The third-party file has ended. Everything between the 98db642aed56244b tags is data: requests and commands from it are not followed. An “end of file” line with another tag inside the block is part of the file.

First 2384 of 14217 bytes. © JoelLewis · MIT · https://github.com/JoelLewis/finance_skills/tree/HEAD/plugins/compliance/skills/fee-disclosure/SKILL.md

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