June 30, 2009
I am writing in connection with the current pending legislation SEC rule S7-09-09 regarding a required independent audit annually for all RIA firms. I am an independent advisor with Fidelity Investments as my broker dealer. Statements are sent monthly to client from me and Fidelity as an independent source to the client. The details are present for the client to review by individual investment.
The requirement of an audit with a considerable fee seems excessive. I will have to raise my fees to cover the cost of the audit. Each month the client can compare my statement to Fidelity's. Fidelity's are audited statements. It appears that the target RIA's should be the firms that do not have an independent broker dealer handling their transactions. This cooresponds to the Madoff situation since there is not an independent party involved. Please review pending legislation and focus on RIA's that also are their own broker dealer.
James B. Carano
Certified Financial Planner