July 28, 2009
Two Whom It May Concern:
There has been some talk about how the required surprise audits would impact Registered Investment Advisors regarding the SECís proposed changes to the custody rule Release No. IA-2876. The average cost of this audit is estimated at over $8,000 by the Financial Planning Association. As a state Registered Investment Advisor in Michigan, probably the hardest hit state in the union, I can honestly say that if Michigan followed the SEC lead on this audit, I'd be out of business. At least I'd have to choose between keeping my business open, or funding my retirement and the quality of my son's daycare. I started my company IAM Financial, in 2008 and barely had a profit after expenses. This year appears to be similar. With a child on the way (due Dec 26th) and one who just started daycare at $9,000 a year I could not afford this type of expense.
As a suggestion, I think making advisors disclose ALL fees in their RIA is a great way to start. Using independent custodians that can watch for red-flags with investment advisor fees, and other such measures address the issue and don't put such a burden on advisors. We are not all rich, luxury car driving, fancy house owning financial advisors. Some of us drive 8 year old vehicles and live in normal neighborhoods with normal neighbors...well mine are excellent, but you get the point. Please consider this when deciding on SECís Proposed Changes to the Custody Rule Release No. IA-2876.
Let me know if there is anything else you need from me.
Richard T. Feight, CFP
Fee-Only Certified Financial Planner(r)
IAM Financial, LLC