June 12, 2009
Hello. I am a fee-only financial planner managing a relatively small client base. I do not take custody of any client funds. I also work with many middle class clients and charge very reasonable fees so that more folks can afford financial advice.
I directly charge my clients my fees and nothing is hidden or confusing about what they pay. Some clients prefer that I take their payments from the custodial account for their convenience. Of course it is more convenient for me, also
Certainly there needs to be some review, such as proposed, of advisors who DO custody client assets. But small advisors who do NOT take custody of client funds would be seriously penalized in time and income by having to follow the same rules just because we take payments via their custodians. I bill the clients separately and they see what payments are deducted directly on their custodian's statements. Most custodians (like TD Ameritrade)have appropriate procedures in place to make sure direct billing is done correctly, such as asking to see client agreements. This makes good sense.
It does not make sense to create so much bureaucracy with the proposed rules in such cases.
Thank you,
John W. Fiege, CFP(r)