July 2, 2009
The proposal to include deduction of client fees from their accounts as custody is absolutely ridiculous! The client is well aware the fees are going to be debited directly based on custodian paperwork at the beginning of the relationship. In addition, the custodian sends them monthly statements which show them any deductions from their account. The only outcome of your proposal will be to create an extra burden on the vast majority of ethical and honest RIA firms. The cost for a surprise audit to a smaller advisor would likely be significant.
I urge you to reconsider and drop this from your proposed rule.
Thank you for your consideration.
Michael J Maye, CFP(R), CPA/PFS,
MJM Financial Advisors, LLC