July 1, 2009
To Whom It May Concern:
I think we all agree that enhanced consumer protection is needed to improve oversight and prevent Madoff-type scandals. However, some of the proposed changes seem more knee-jerk reaction than prudent.
Subjecting RIA firms to additional 'surprise' audits will increase BD expenses, which will ultimately be passed on to consumers. It seems much more prudent to me to improve the current mechanisms, as has already been done by the SEC closing the loophole regarding registration for certain accounting firms with the PCAOB (that Madoff's accountant used to avoid detection of its phony auditing!).
Also, I'd like to see an increase/improvement in the training of SEC and FINRA personnel who clearly were remiss in their duties to enforce current rules. Let's have an investigation into why they ignored repeated warnings of whistle blowers! (What an embarrassment!!) Accountability, please!!