July 6, 2009
I am opposed to the proposal to require independent surprise audits for registered investmnet advisors who have the ability to deduct their fees from clients' accounts held by third party custodians. I have been a RIA for one year, after being affiliated with a broker-dealer for almost seven years. Building and managing a profitable independent practice is difficult enough as it is for a small business owner. The requirement to pay for an indpendent audit would be so onerous and time-consuming that I would probably shut down my practice and move on to a different profession, such as the one I left (petroleum geoscience).
This proposal really serves no helpful purpose for clients like mine, who already get quarterly statements from the custodian, and also concurrent fee statements from me, which concur with each other. If an advisor were to abuse the ability to deduct fees from their clients' accounts, I suspect that the custodian would put a quick end to it.
I think it will create the opposite effect from what is intended, driving many small advisors who really care about their clients and serve them well, out of the business.
Kim C. Christensen
Certified Financial Planner (TM)