July 2, 2009
HFH Planning Inc. is a firm that charges on an hourly basis. Having to go through an expensive audit would be a reason to not offer the convenience of debiting the clients' account at TD Ameritrade. Collecting those fees would be an inconvenience to the client and serve no practical purpose. Further, this type of audit would not have prevented the Ponzi schemes that are driving this rule change. Closer examination of the due diligence firms use prior to investing in non-public investments could accomplish that end with fewer man hours and lower cost. And, of course, it is the clients who ultimately have to absorb that cost.