July 1, 2009
I do not think that this should apply to RIAs that have an independent custodian and just debit fees from client accounts. There has been no abuse in this area and it will just be an unnecessary expense for a small business like ours to have a surprise audit annually. Please exclude from the definition of custody the ability to debit fees from client accounts if held at an independent custodian.
David Daughtrey, CFA, CFP®