I think a more flexible definition of "small" is warranted. Consider some of the facts related to the size and scale of my business: 1) Personnel: I am the sole owner, the sole operator, the chief compliance officer, the head of strategy, planning, trading, marketing, supervision, reporting, client relations, etc. Operations are highly centralized within the walls of a single home office. 2) Client Base: The firm manages money for 16 households, of which 5 are family members and 6 are close friends. All clients are accredited investors, except one who is the mother of a close friend. We aren't looking for new clients, and don't advertise actively. 3) AUM: One household anchors the business with over $100M of AUM/AUA. We could shed clients and operate as a family office, but for now, we're taking the high-road. If we grow assets by 10% (read small change) this year, we go from "small" to "no longer small". In contrast, if we lose 10% of assets the following year, we revert to small. I submit to you a fact that appears plainly obvious to me: under such a scenario, nothing really changed. The firm was always small. Even with 2x the AUM or more, and all else being equal, it's still a small firm. Compliance is a burden to all advisors, but can be unfairly disproportionate to firms who don't have the resources available to larger firms. If the goal is to eliminate the incentive for individuals to work for themselves as sole-proprietors, then change nothing. The current system will eliminate small firms eventually. If you see the application of the regulations as disproportionately burdensome, then start with a definition of small that takes into consideration the the number of officers, employees, and owners; and also the number of clients, particularly non-accredited clients. Warm regards, NPM