July 10, 2009
To Whom It May Concern:
As a Certified Financial Planner and member of the Financial Planning Association, I fully support the efforts by the SEC to strengthen consumer protection, particularly in light of the Madoff and Stanford scandals, but feel that outsourcing audit responsibilities to independent accountants is not the best way to accomplish this.
A better solution is to provide the SEC and its staff with better training and resources, including professionals with the requisite financial and quantitative backgrounds to understand complex trading strategies, and a dedicated staff to oversee compliance at RIA firms. Independent CPAs may or may not have the necessary training and experience to fully understand the RIA and financial planning business, standards of diligence and care will likely vary from auditor to auditor, and the door is left wide open to a variety of abuses.
I sincerely hope that the SEC will continue in its efforts to bolster regulation within the financial planning and RIA industries in a comprehensive and meaningful way. Honest practitioners around the country and the world have every interest in seeing an outcome that ultimately benefits the end consumer.