Subject: S7-25-22: WebForm Comments from Adrian Day
From: Adrian Day
Affiliation: Investment Advisor

Dec. 18, 2022

December 18, 2022

 Like so many proposed SEC rule for Advisors, this might sound reasonably at first blush.  I mean, after all, wouldn't advisors want to conduct due diligence before outsourcing critical tasks?

And that's the whole point: we don't need the SEC to tell us to do this.  And we certainly don't need the SEC to introduce a set of rules and disclosure around this basic function, which, once the lawyers and compliance industry gets hold of it, will turn into a whole  new set of \"policies and procedures\" with minute rules to trip us up.

Only the SEC could propose a rule of 232 pages on something so simple.

Believe it or not, most advisors are both honest and honorable and also want to run a professional, efficient business.  We also want to focus on our clients. Constant rules getting into every minute detail of running a firm, with time-wasting policies and procedures, meetings and reports, only takes us away from our critical role of looking after our clients.

Why don't you focus your efforts on trying to stop fraud BEFORE it happens, instead of sitting around dreaming up new rules to make out businesses more bureaucratic but not iota more beneficial for clients?