July 9, 2016
I am a sole practitioner managing less than $10M in assets. This set of rules, while admirable, is beyond the needs of my clients and my capacity to comply with. I suggest that the rules should only apply to advisors of above a certain size of assets under management and/or number of employees. Incidentally my clients assets are held in brokerage account in their name and my advisory contract is automatically cancelled if I should die, and can be cancelled by my clients at any time.