July 2, 2009
Ref: Contemplated changes for SEC registered firms, Custody triggers for outside audits
This is a good idea in general. However, firms which take fees from their client accounts should not be considered as having custody if they were to comply with certain standards.* In Michigan, we comply with Michigan Corporation & Securities Bureau Release No. 93-3-BD, attached.
As a small firm, not having the exemption (93-3-BD), would devastate our cash flow, would add administrative work, and obviously greatly increase postage costs. Also, quite frankly, I think it is ethically bad idea for the clients to have to mail in their fees (unless there is a tax reason). Some clients would delay payment just because they can which does our small firm and the clients no good.
I.e. Any enacted new regulation should exempt certain firms which deduct fees from their clients’ accounts.
Haynes Financial, Inc.
148 E. Grand River Rd. Ste. 107
Williamston, MI 48895