June 8, 2015
The proposed Amendment to Rule204-2 requiring the maintenance of all communications of performance to a single individual (rather than currently 10 persons) DOES NOT clarify communications to existing clients of THEIR OWN portfolio's performance. Advisers are often asked by clients to provide the performance of their portfolios NOT the performance of any general portfolio holdings by the adviser. The client has both monthly and quarterly statements to verify their holdings and as such it would not seem necessary to keep every communication to clients of their own portfolio's performance over the time period provided which would often differ from any general performance data run and distributed.
I believe clarification would be helpful if the amendment is adopted.