July 13, 2009
To whom it may concern,
As a member of the FPA, Sec registered investment adviser and a CFP® , I am strongly opposed to the requirement in the proposed custody rule. This appears to be a knee jerk reaction to the Bernie Madoff scheme and political grandstanding.
The new surprise audit requirement will add additional costs to my business. Not only with these costs need to be passed on, but it will also take time away from working on real client issues.