June 10, 2009
As a registered investment advisor I believe this would put an uneccesary financial burden on firms that have and continue to follow the correct practice management. If a firm is going to misappropriate funds, I do not feel a suprise audit would stop them. This goes back to punishing firms following the rules for the very small amount that break them. During a normal SEC audit this issue is already being addressed. This would be cost prohibitive, disruptive as well as something that I do not feel would solve the problem.