July 1, 2009
I have read with interest and concern about the proposed custody rules as it concerns fees debited from accounts. The surprise audit costs would be tough for small independent firms such is mine. Mailing invoices will also hurt cash flow as some clients don't pay bills promptly.
The fees could be withdrawn with an immediate email or letter to the client outlining the fee and how it was calculated. During inspections, the examiner could ask for these files. Our clients want to debit fees as a time saver for them. The fees are reflected in their monthly statements and are very plain at Charles Schwab and TD Ameritrade.
Thank you for hearing me on this matter.