July 2, 2009
We are a very small firm (one advisor with two operations employees). We are a fee-only firm, so the dramatic decline in stock valuations has affected us greatly. Our revenue is down about 25%. Imposing this rule would mean an additional expense burden on top of this decline. The SEC already has an audit schedule that should cover issues important to investors. I don't think it's fair to let those few bad apples (Madoff et.al.) to create an extra burden on those of us who are honestly assisting our clients. If the SEC had heeded complaints about these bad apples, we would not be facing this. I think the answer is to shore up SEC policy and procedure to protect investors.