June 17, 2009
This proposed rule, if enacted, would present a severe hardship for small businesses like ours. We can except the surprise inspection provided I am available and not in a meeting, out of town or on assignment outside of the office, as I have only one part-time employee who is not a principal and does not have authority to assist with an inspection. Regarding the requirement of an annual audit, as a former auditor I am fully aware of the requirements and recognize that this requirement is ineffective in preventing fraud as is generally stated in the engagement letter provided by the auditor. The requirement of an annual audit would propose substantial hardship and cost that a small business like ours can not bare. Therefore, there should be a small business exception or this may force us out of the business.
Roger S. Asel
Certified Financial PlannerŪ
Certified Public Accountant
Personal Financial Specialist-AICPA
President, Certified Financial Strategies Corp.