July 22, 2009
As a member of a registered investment adviser with the SEC, I am strongly 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.
I do not believe the proposed surprise audit would be an effective regulatory response to the recent scandals in this industry. I believe the proposed surprise audit would put undue and unnecessary burden on smaller SEC-registered investment advisers.
In my opinion, this proposed rule is a result of recent scandals that had nothing to do with an advisorís ability to deduct fees from a clients account.
In order to enhance consumer protection, I would support Congress appropriating additional resources to the SEC to hire and train additional examination staff to increase the regular audit cycle of investment advisers.
Thank you for considering my opinion.
Allen B. Kaufmann
SilverOak Wealth Management LLC