July 16, 2009
SEC,
This proposed regulation will do nothing decrease the likelihood of fraud on the part of RIAs. The firms for whom this proposal was initiated (Madoff, Stanford etc.) were already subject to this rule. As RIAs with custody of client assets, they were subject to a surprise audit requirement by a public accountant as well as regular inspection by FINRA. Moreover, the result of this proposal will increase client fees as advisory firms simply pass on their additional costs of compliance. I ask you to please reconsider the proposed regulations. I believe that better enforcement of existing rules would be a better solution for all. Thank you.
Stefan Garcia, CFP® MBA
Monitor Wealth Group