July 28, 2009
RE: File Number S7-09-09
I am an SEC registered investment advisor. 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.
As a small investment advisor, the time and cost of such an ammendment would be detrimental to my firm and its clients. As far as I am aware, none of the recent scandals in our business have been as a resullt of improper fee deduction.
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.