Subject: onerous requirement for tiny LLC
From: Easan Katir, Managing Member
Affiliation: Cube Point LLC

December 19, 2019



Dear Sir / Madam, 


The California DBO, based on SEC rules, insists that because I am a RIA, I need a PBAOC audit each year for a tiny $500,000 in assets LLC with 8 members.  Last year this cost about $7,000, and that was the low bid.   This is an onerous regulatory burden for such a small entity, and could be easily remedied by amending the rule to say it applies to pooled assets of $5 million or more. 


Hope you will consider my suggestion favorably. 






best regards, 

Easan Katir 
Managing Member 
Cube Point LLC 
[redacted]