Feb. 25, 2023
Dear Sirs or Madams, As a small firm with not quite $100 million in assets under management, we do not have the resources available to read all 434 pages of the proposal regarding “Safeguarding Advisory Client Assets.” I’m sure much in the proposal makes sense. For example, our firm does not believe that any asset types should be beyond the purview of qualified custodians. However, I have heard that discretionary trading authority—alone—would be enough to trigger “custody,” according to this new rule. This seems burdensome and unnecessary. Please do NOT make a rule for it to be “custody” for advisors merely to have discretionary trading authority. Thank you!! Todd Calamita, CFP® , CDFA® www.calamitawealth.com