July 16, 2009
I strongly disagree with the proposed surprise audit requirement for RIAs. This will add an unnecessary cost that will be at least partially passed on to the consumer. If the current rules had been enforced on Madoff and the other crooks we wouldn’t be talking about this.
For RIAs that use a qualified custodian and that custodian provides a monthly transactional statement, this requirement is overkill and will add no value to the investing public. If you want to do something useful, define a standard of conduct, qualifications and experience for ALL investment advisors. It takes more training to be a barber than someone who holds the responsibility for a family’s financial future in their hands.
Barry Bailey CFP® AIF®
Owner/Investment Advisor Representative