March 9, 2022
It seems especially of late, the SEC has proposed a flurry of rules all of which will have the net effect of continuing to crush small business (smaller RIAs) who have limited time and money resources to adapt and comply with the burdensome and ultimately pointless check the box responsibilities.
As it relates to this rule in particular, the one little piece snuck in there regarding written documentation of an adviser's reviews is absurd and takes time and resources away from servicing clients which is what we are in the business to do--to help individual investors navigate complicated financial issues.
Further, the proposal states:
\"Our examination staff
relies on documentation of the annual review to help the staff understand an advisers
compliance program, determine whether the adviser is complying with the rule, and identify potential weaknesses in the compliance program.\"
Basically, what the SEC is saying is we need
a better cheat sheet for our examiners (who average 175-200k+ a year in salary and benefits) to fine firms for petty rule requirements. I was under the impression that Americans had a right against self-incrimination, but I guess that only applies to people and not small businesses.
It seems the SEC does not care about smaller advisers who are actually helping retail clients with their finances, the SEC is just looking to pile on more regulation to appear busy and virtue signal about how much they are doing to protect retail investors, meanwhile cryptocurrency scams are running amok pumped by youtube promoters who all disclaim \"this isn't financial advice, i'm not a financial adviser, but let me tell you about this coin and how i'm trading it.\" Absurd.