July 17, 2009
The proposed custody rule (IA-2876) is a poorly conceived idea to which I strongly object. For us to have an annual surprise audit by an independent public accountant is beyond belief. We are already supervised by the SEC and are subject to a surprise audit at any time by an employee of the SEC.
We strive hard to comply with all applicable regulations for registered investment. It is unnecessary, unwise, expensive and an ill thought idea to impose a surprise visit by an independent public accountant.