July 2, 2009
To the SEC:
The fee only IRA industry is practically and virtually free from conflicts of interest. The Madoff/Stanford scandals are instances where both brokerage and so-called investment advice were combined. The "fee only"IRA should not be made to suffer for the crimes of these two outliers who were allowed to act as custodian as well as providing "advice" at the same time with no third party oversight and accountability.
The surprise audit proposal under IA-2875 is unnecessary and would simply add another burden on the already highly regulated IRA industry. In most cases the client fees are computed through software programs provided by third party vendors. The fees are submitted back to the IRA by third party custodial services that have no pecuniary interests in the IRA. In addition the client is sent a duplicate billing, so all parties are fully aware of the basis and the amount of the fees .
Under the circumstances described above what value would an audit be except of course to audit firms?