June 30, 2009
The Madoff and other schemes uncovered by the SEC had nothing to do with fees deducted by investment advisers and new regulations in this area would be unnecessary, costly and burdensome for small, independent investment advisers.
The new surprise audit requirement will add additional costs to my business that will ultimately be passed on to my clients via higher fees to make up for this cost.
In order to enhance consumer protection, I would support Congress appropriating additional resources to the SEC to hire and train additional examination staff to increase the regular audit cycle of investment advisers. I even know someone in the current 9.4% unemployment stats who would be a great asset to them.
Thank you very much,
Neil Brown CPA, CFP®