May 29, 2009
I am a SEC-registered RIA with 110 clients and approximately 360 accounts. At present, I am the sole advisor with 3 full time support staff. Should the proposed rule be enacted, I estimate my annual direct costs at $10,000 to $15,000. This would represent my third largest expense after staff salaries and rent. I feel I would have to pass this onto my clients in the form of a specific "SEC Audit fee" and it would likely add @ $100 per year per client.
I fall under the category of an advisor who solely withdraws assets from client accounts for payment of fees. I custody with Fidelity Institutional Services. Fidelity provides monthly statements and all disbursements from the clients account are clearly identified. Under the circumstances, I feel the audit proposal is burdensome, expensive and of no ultimate benefit to my clients. Requiring advisors in my circumstances to provide a notice to clients urging them to compare their monthly account statements from their custodian to my quarterly performance reports would be marginally helpful and the cost of compliance would be minimal. It is also my understanding that Fidelity will not process withdrawals that exceed 3% per year
I believe that the proposed rule has no benefit but imposes significant costs on clients of advisors that custody with a "qualified custodian" who sets reasonable limits on annual withdrawal percentages and provides monthly statements that clearly identify all disbursements.