June 12, 2009
While my own S.E.C. Registered Investment Advisory firm is large enough to incur the additional costs associated with the proposed custodial rule, many honest and hard-working investment advisors whose practice is as much a calling as a business and who care very much about their clients will be forced out of the business. This may be good for larger firms like my own by virtue of the reduced competition, however it will be disasterous for the clients who will be forced to return to commission-based stockbrokers and insurance agents. The proposed rule does absolutely nothing to protect consumers. It serves only to create a barrier to entry to independent advisors, and to help return lost market share to the very firms who have historically done the most consumer harm.