June 30, 2009
We feel the rules regarding custody and the requirement for an independent annual audit are not necessary for advisors who only deduct fees from client accounts with a qualified custodian. We utilize a qualified custodian who is sending out statements to our client and we send out fee calculation and payment status information each quarter to our clients. This seems to be redundant and very costly to require an audit in addition for the smaller firms like ours.
Please consider an exemption for advisors who deduct fees from qualified custodians.