Subject: File No.
From: Adrian V Day
Affiliation: President, Adrian Day Asset Management

August 8, 2016

Though this may sound reasonable, the truth is that business owners—per business owners, not because of some SEC regulation—plan for the continuation of their business.

An SEC rule even on a basic and reasonable issue such as this morphs into countless hours and energy with compliance officers who always interpret SEC rules in the broadest possible manner, countless hours and energy on forms, meetings, training and so forth.

Most small RIAs really want to devote their time to servicing their clients, including managing their portfolios. The more time spent on compliance and rules is less time spent on doing what their should be doing, to the detriment of clients.

For goodness sake, stop keep piling on new requirements and rules, or there will soon be no time left for anything else.