On January 26, a cease-and-desist order was announced between the SEC and the bank regarding alleged violations involving unauthorized advisor fee overcharges affecting at least 60,000 advisory client accounts. The order claims that during a 15-year period, the bank failed to confirm the accuracy of billing rates entered into its computer systems in comparison to fee rates outlined in client contracts, billing histories, and other documents. Furthermore, the order alleges that the bank cannot locate approximately 83,000 advisory contracts for accounts opened from 1990 to 2012, preventing the bank from accurately validating the fee rates billed to clients over the years against the fee rates that were negotiated when the accounts were opened. As part of the settlement, the bank agreed to enhance its fee-billing and books-and-records practices, and will pay an $18.3 million fine.