July 24, 2009
I just want to be sure you understand how needless and fruitless a surprise audit would be for RIA's who custody funds only to the extent that they debit fees from a client's account. In our case a separate and completely independent custodian sends monthly statemnets where all trades, transactions and fees are clearly delineated.
To what extent will the proposed rule help a client? This new rule will unmistakenly increase costs to clients, pull a small businesses focus away from serving those clients, and thereby reducing the value one can add to the customized advise, daily service protocol, and overall client experience that they now enjoy.
Please do not burden RIA's, those who hold limited custody, defined as those RIA's with fee only drafting abilities, with this proposed rule. Enforcement is key, not new and ineffective and burdensome rules.
Thank you,
David Partheymuller