July 27, 2009
To Whom It May Concern,
As a CPA and a CFP, I have mixed feelings regarding this proposed rule. As a CPA, I would welcome the additional business. Our accounting firm could do these audits during the off season. They should be straight forward audits without many complications. As a CFP, I believe that this would be a terrible rule. It would create an extra burden on financial planners that would not accomplish much. I find it comparable to setting up road blocks on every road to catch drunk drivers. Yes you may find a couple of more drunk drivers, but in the process you would snarl traffic for miles. I think you have to ask yourself if this audit rule was in effect with the recent scandals, would these unscrupulous advisors have been caught. From my understanding, the answer would probably be no. I ask that you please think through the unintended consequences before you rush to make new rules.
Sincerely,
T. Scott Harding, CPA/PFS, CFP
Harding and Hittesdorf, P.C.