July 15, 2009
Dear SEC:
I'm a small Advisory Firm with $40m under management. I STRONGLY OPPOSE your proposal to have an independent audit on my advisory fees conducted by a CPA. This requirement is extremely harmful, expensive and misguided. As a small SEC registered firm, you would force me to raise fees and spend less time managing client assets.THIS IS AN EXTREMELY BAD IDEA!
Sincerely,
Brian Carruthers, CFP,CMT
President/Principal
Brian Carruthers & Associates