July 22, 2009
Subject: File No. S7-09-09
From: Strategic Wealth Management Group, LLC
Affiliation: SEC- Registered Investment Adviser
In regards to the proposed amendments to the custody rule that would subject investment advisers to a surprise audit by accounting firm, we are opposed to this requirement.
The new surprise audit requirement will add additional cost to Investment Adviser business. It is not warranted as many investment advisers do not possess actual custody of client accounts but are categorized to have custody because they debit advisory fees directly from their client’s accounts. The client signs authorization in the contract between the investment advisory firm and the on the account application. The clients receive monthly statements from the independent custodian. The statement clearly notes the investment advisory fee. It is an unwarranted hourly cost for Investment Advisor firms for a “surprise” audit by a CPA to review verification of advisory fees debit from the client’s accounts.
Gary P. Desjardins, CFP®, CRPS®
Accredited Investment Fiduciary™
Strategic Wealth Management Group, LLC