July 8, 2009
The proposal that would mandate audits for those that are viewed as custodians simply because they debit fees from client accounts (with client permission) appears to miss the mark. A much more effective and less costly proposal would mandate that those that actually hold the client assets (the broker-dealers) filter the fee debit process to make sure that fee amounts do not exceed a pre-determined level. The current proposal sounds like something that would be written by the large investment firms with the goal of heaping additional costs on the "little guy", their competition. We "little guys" are actually serving the clients best, by staying close to the clients and accomodating their individual needs rather than trying to fit them into the big company "cookie cutter" approach.