June 30, 2009
In response to the proposed rule change, I would make the following comments:
This is very harmful to small advisors (less than 100M under management). We would mostly likely have to cut jobs, salaries, reduce health benefits, or a combination.
Second, while I believe it is good idea to make sure there is not another “Madoff”, the audits should be limited those firms that do not have an independent third custodian that processes fees. The greatest risks lie with those firms that do not have a third party, independent custodian.
Your consideration is appreciated.
Brian T. Sells, CPA CFP
President & Chief Investment Officer | Peak Financial Advisors, LLC
50 South Steele Street
Denver, Colorado 80209