June 10, 2002
Securities and Exchange Commission
This letter is a comment to a proposed Investment Advisory (RIA) rule change regarding Internet Investment Advisors who "provide substantially all of their advisory services through Internet Web sites. Clients visiting these answer online questions about their finances...."
This is a description of the services we provide but as yet we can't register with the SEC because we do not meet the $25,000,000 threshold.
Since starting TheTimer.com (registered in Utah and California) marketing has been extremely difficult because of the registration requirements of the National Securities Markets Improvement Act of 1996. We have ignored many out of state client and advisor inquiries.
We would encourage SEC registration for web-based advisors. Without it, we constantly feel some state is going to have a problem with us. We feel like we are in a bit of a no-man's land on registration. Our platform does reach across state borders and is intended to, but is hamstrung until we get to $25,000,000. We have been rejected by some national advisory firms on that issue alone when otherwise we would be a perfect fit for the type of service they offer.
Although there may be few web-based advisory services now it is going to get much bigger. The web is a perfect medium to deliver advice if done properly. Over the web advisors can get as broad or detailed as needed. Web technology is getting more and more personal. Already we can talk directly to and see others visually on the web. Our business is evolving into a "virtual office." I would be happy to give you a demonstration of our virtual office.
Although we don't use the total virtual office just yet we are only a few years away from doing so. In the meantime our entire advisory service is designed to run completely on the web.
A national registration for our service would remove a significant headache caused by the 1996 change.
I would be happy to discuss our services and show our site to anyone at the SEC.
David L. Garrett