July 9, 2009
Ladies and Gentlemen,
I have been a Registered Investment Advisor since 1982. I wish to comment on the proposed rule that would subject Advisors to surprise audits if they debit fees from client accounts. As a relatively small firm, the cost would be onerous and force us to discontinue this practice, which in turn would raise our cost of collections which we would have to pass along to our clients by raising our fees. It would also be an inconvenience for most of our clients, over 90% of which currently choose to have their fees debited rather than pay by check.
We have never sought custody of client assets nor collected fees in advance and have no intention of doing so in the future. The proposed regulation will likely not prevent Madoff-like abuses but will simply raise the cost of doing business for the clients of legitimate advisors. I urge you to drop this proposal. Thank you for your consideration. Sincerely, James P. King
James P. King , CFP
J.P. King & Associates, Inc.