June 15, 2009
My firm, Couture Financial, Inc. provides active management for our clients and have since 1988. I have been careful to structure the client accounts through an independent trust company so that we never have access to the clients money.
I am very concerned that this new potential rule could require us to have these audits simply because we have the custodian calculate and bill our management fees directly to the clients account. I have made it a point to keep all of these functions completely at arms length to protect our clients and eliminate the potential for conflict as much as possible.
Please reassess this requirement as it might apply to a firm such as ours as it would cause a great deal of additional work and probably cause us to have to hire additional staff in addition to an audit firm. It would then be necessary for us to increase our fees and would end up being an unnecessary additional expense to our clients.
I appreciate the opportunity to express these issues for your consideration.