July 27, 2009
Most IA(s) use 3rd party custodians for their clients' assets. I think it would be a hardship and overkill to require IA(s) to go through a surprise audit for debiting management fees. Our clients receive Advices for their management fees and they also receive monthly/quarterly custodial statements.
This rule should not be approved.
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Regards,
Patricia Melnick
Administrative Director
Seaward Management