July 25, 2009
I have a very small RIA firm which I normally do not advertise nor prospect for (under $10mm in assets) and the fact that the SEC File No. S7-09-09 surprise audits are appalling. The few clients I have have 1 thing in common they do not want their information be seen by other entities unless it is related to government or THEIR accounts.
By having independent accountants reviewing their assets, you are setting up a disaster waiting to happen Just because some of the independent accounts may have "clean" records, does not mean they have not taken client information and put it into personal use. Remember, MADOFF had a clean record aswell and you failed
My custodian (TD Ameritrade) has been watching over my transactions on a regular basis and they have done an exceptionally well job with the safety and concern of my clients. TD and I have the same goals in mind for the clients and that is why it is safe for THEM to be the eyes in ears.
Please remember the SEC ruling in 2003
The fees relating to the surprise audit will force me to increase my fees by nearly 100% I charge VERY low fees with a spread so low that I do not make any money (which i would be happy to show).
File No. S7-09-09 is counterproductive in client safety. I will discuss this with my clients and will petition against this. You are setting up every investor up to only God knows what with "another set of eyes"