July 8, 2009
To Whom it May Concern:
I am the owner of a small investment advisor. I manage mutual funds only and charge clients a fee for both that and financial planning. Their assets are held by a large broker dealer (NFS). According to your new proposal, I would have to have a surprise inspection by an outside auditor or CPA annually because we debit our fee directly from our clients' accounts.
I understand the need for greater oversight when advisors truly have custody of clients funds, but our client's custodian sends out monthly statements to compare our fee against. The burdens placed on us by the SEC already take a heavy toll in both time and money. This annual cost will definitely lead to my having to let go of an employee or stop giving clients statements from our office to cover the cost of this audit. Please amend the rule to not force advisors to pay for an audit simply because of clients agreeing to pay us directly from their investments.
Casey D. Hunt, CFP®
CERTIFIED FINANCIAL PLANNER™ professional
St. Louis Financial Planners, Inc.