June 23, 2009
Please accept this comment regarding the proposed Custody Rule. As a fee-only NAPFA registered advisor, I strongly disagree with this proposed rule of requiring firms who only have fees withdrawn from client accounts to be considered "having custody." Currently, our firm deducts our fees from client accounts and the vast majority of our firm's funds are held at Charles Schwab. They actually monitor us to make sure our fee deductions are within appropriate limits. If our firm should, and we have not, exceed that limit, Schwab has the authority to deny our request. I agree with this monitoring and fully support it. To suggest our firm has custody when we have this limit on us, seems to be inefficient and needless.
In addition, currently our small firm, would be burdened economically by the required CPA audit of our firm, which after investigation, could cost upwards of $10,000 per year. This requirement would be an economic hardship and we strongly request that the SEC not put this Custody rule into effect.