August 18, 2009
To Whom It May Concern:
We live in the 21st Century, a world of online banking and finance which includes the universally popular feature of automatic bill paying.
In this context, automatic debiting of advisory fees is a time-saving convenience which our clients expect, and a cost saving, paperwork-reduction tool for all concerned.
Independent advisory firms with fiduciary responsibility, especially smaller ones such as ourselves, should not be penalized with the prospect of costly, onerous audits for continuing to offer the convenience of automatic bill paying to our clients. In our opinion, this would be an unjust and misguided rule change, which might have the unintended consequence of making it increasingly unattractive for smaller firms to start up and remain in business.
Therefore, we respectfully urge the SEC to exclude debiting of fees from the proposed Custody rule changes, which we otherwise support. Thank you for your consideration.