June 9, 2009
The idea of requiring an annual audit for Advisory firms that do not custody assets is overly burdonsome. We are already required to do a mock audit every year. Adding another 8000-15,000 in fees for a smaller firm like our is difficult to stomach.
In addition, though I would understand if we were holding clients assets in-house, most repudable firms do not. The idea of having this level for just being able to debt and account for fees is silly. By all means limiting the annual amount of fees that can be debtited (to say 2-2.5%) might be reasonable. Or requiring an audit for firms that do performance based fees might be reasonable say every three years
Thanks for your consideration and please feel free to follow up with questions.
Jonathan Kelley
Partner Hinds Financial Group