July 10, 2009
The proposed custody rule (IA-2876) as put forward by the SEC on May 20th, 2009 is not only unnecessary but also unreasonable. Most clients agree in advance to have our management fee deducted from their portfolios. When our quarterly fees are deducted, the client receives a confirmation of the trade. The payment method of paying our fee is contained in our client agreement. There is the occasional client that wants us to bill them which we are pleased to do but the majority prefer their fee deduction from their investment account.
Having just been subjected to an SEC audit, we feel the SEC has the opportunity to provide oversight without requiring the expense of an outside auditor.
Please do not approve IA-2876.
Thank you,
Thomas H. Burkhart, CEO
The Savant Group