May 29, 2011
Dear Sir or Maam,
I am writing today as I review the proposed 17 CFR Part 275 Investment Advisor Performance Income. As I read the proposal as posted in the Federal Register, I was struck wondering why the Federal Government wants to allow a review only every five years. On the surface, this appears to be generous to potential clients, but is doing so at the expense of the contracted investment advisor. Your office even goes so far to include suspicious, quantified data to support the claim as to how few advisors will be affected by such actions.
There is another aspect which I find to be questionable, and that is the continued reduction in the ability for an individual to choose freely within the marketplace. The proposed regulations intentionally reduce the number of potential clients/consumers by reducing the means by which a persons net worth is calculated. Your intent is to protect consumers when in fact it prohibits them and has potential to harm. By reducing the number of options if investment schemes, there are less opportunities for a tailored investment plan as deemed by the consumer.
Lastly, we are in a time when the dollar is intentionally being devalued by the US Government on a near monthly basis. The actions of quantitative easing, also understood as monetizing the national debt, are not controllable by any private citizens or corporations. This devaluation will continue to occur as long as the Fed is not restrained by Congressional action. I can see no state of fairness in capping a persons income while simultaneously reducing the value of that income.