Subject: proposed custody rule (IA-2876) s7-09-09

To Whom it May Concern,

I am writing to express my disapproval with the proposed custody rule (IA-2876). I am a Principal at an RIA and I believe that the audit requirement in this proposal is excessive and cost prohibitive. Small RIAs already operate within the costly and time consuming confines of the existing regulatory framework and there is no need to impose further burdens on us. The fact that we are able to deduct advisory fees directly from our client accounts does not justify the additional regulations because these are already covered within existing rules.

The requirement to have a surprise onsite audit on an annual basis will do nothing to stop fraud. This will only hurt small business!


Anthony Josephson
Carmel Capital Partners