July 7, 2009
To Whom It May Concern:
I am a member of the Financial Planning Association as well as a CPA and Candidate for Certified Financial Planner Board Certification. I am also a SEC-registered investment advisor.
I wish to express that I am opposed to the requirement in the proposed amendments to the custody rule that would subject investment advisers to a surprise audit by an accounting firm. The cost of this revision is not cost effective and appears to be a political reaction to the recent events rather than a well thought-out change.
Donn Merrill, CPA, Candidate for CFP Board Certification