July 1, 2009
I am a member of the FPA (Financial Planning Association) and I am opposed to the requirement in the proposed amendments to the custody rule that would subject investment advisers to a surprise audit by an accounting firm. It would appear that this proposed legislation is reacting to Madoff and other Ponzi schemes which had nothing to do with fees deducted by investment advisors. These new costs would add additional costs to my business that would ultimately be passed onto my clients. Unfortunately, my clients are not billionaires, they are middle class America trying to save enough money so they can eventually retire. This proposed legislation, as currently proposed, would affect the wrong portion of the population.
I would support Congress Appropriating additional resources to the SEC to hire and train additional examination staff to increase the regular audit cycle of investment advisors. Please reconsider which approach would be best to achieve the results you are looking for. As far as I am aware, there have been no systemic problems with fees deducted by investment advisors and this legislation would cause great harm to small, independent investment advisors.
Melinda Thomas, CFP, ChFC, QPFC, PRP
FIT Financial, LLC.