July 1, 2009
Dear sir or madam,
If I had to hire an independent auditor, each year, assuming it would cost about $2,000, it would use up 4 months of my surplus cash. Since last Fall,
I have been in survival mode. My business is down about 60%, and costs are slightly higher. My goal is to survive until the economy recovers.
I have authority to debit fees from customer accounts through TD Ameritrade. Why do I debit fees directly? Because clients do not pay invoices in a timely manner. I have one client who asked me to bill him by mail instead of from his account. He is a successful divorce attorney in Hinsdale, Illinois. He is now 3 quarters behind in his payments. Some people just never get around to doing things that they think are too small for them.
My fee is only 50 basis points per year. Some advisors charge 4 times this much. I would like it the best if TD Ameritrade could create billing for me automatically. I could tell them what my rate is for each account and they can send me a check automatically. I think this would be the best method.
The proposed changes will affect investment advisors who are deemed to have custody of client assets in any of the following manners:
* Through affiliated custodians
* Through the ability to take fees from client accounts
The proposed custody rule (IA-2876) will subject SEC-registered investment advisors who have the authority to debit advisory fees from clients? custodial accounts, to undergo an annual surprise audit by an independent public accountant.
The cost of such an audit could be significant ? and will depend on the number and type of advisory accounts your firm manages.
The SEC is seeking guidance from advisors like you. Comments on the proposed rule changes are due by July 28, 2009. TD AMERITRADE is in the process of reviewing this proposal and formulating our comments to the SEC. Visit the SEC web site to make your voice heard and see what your peers have to say. You can also submit your comments by email to email@example.com. Please include 'File Number S7-09-09' in the subject line.
For additional questions please contact your Sales Vice President or Service Team.
------------------------------------------------------------- Joseph J. Alotta
Certified Financial Planner™
Registered Investment Advisors
Certified Fund Specialist
Registered with National Association of Personal Financial Advisors Fee-Only™
New York University, MBA Finance (cum laude)
New York University, BS, Economics (cum laude)
DePaul University Certificate in Financial Planning