July 14, 2009
I think the number one issue we as financial intermediaries and fiduciaries face today is to make sure our clients and the general public is assured of their money's security from all malfeasance by parties dealing with their assets, their money. And also we have full accountability and responsibility for our actions and must comply with every letter of the law. That however is not a reason to pass laws or make rulings that pretend to be filling in perceived holes in current legislation when in reality they are only diverting the responsibility of those that have had the oversight,which failed in the last several years. This proposed rule would impact over 9,600 advisory firms and would force many of them to pay for the auditing services of PCAOB (Public Company Accounting Oversight Board) members, primarily the Big Four. I think the key phrase in modern governance is that it has to be effective and efficient. In this information age there is no reason we can't have both. Certainly there is a way to inform clients of the surety of their money without creating the mindless drudgery of personal visit audits. Rather than repeat the mistakes of the past, let's set a new tack toward high efficiency, low cost, technology based solutions that satisfy everyones needs. In this day and age, by now, we should have learned that simply making people spend money is not the solution to our problems. Effectively creating a level playing field for all would be a more efficacious journey. I am totally against the proposed SEC ruling.