July 21, 2009
My name is Evan P. Welch, and I am member of FPA Massachusetts and an advisor with a SEC-registered investment adviser (Ameriprise Financial).
I am opposed to the requirement in the proposed amendments to the custody rule that would subject investment advisers to a surprise audit by an accounting firm.
The proposed surprise audit appears to be a politically motivated reaction in wake of the Madoff scandal, rather than an effective method for protecting the public. The Ponzi schemes recently uncovered had nothing to do with fees deducted by investment advisers.
The new surprise audit requirement would add additional financial costs to our business, that, unfortunately, we ultimately would be forced to pass on to our clients. In addition, we would have even less time to focus on our core mission: helping our clients achieve their investment and financial goals.
As an alternative, to protect consumers, clients and the public, I would support Congress appropriating funds to the SEC to hire and train additional examination staff to increase the regular audit cycle of investment advisers.
Evan P. Welch, CFP