July 22, 2009
Dear SEC official:
I received the following email. My comments follow this email.
Dear SEC Registered Adviser,
The proposed custody rule (IA-2876) - http://www.sec.gov/rules/proposed/2009/ia-2876.pdf as put forward by the SEC on May 20th, 2009 would subject all SEC registered investment advisers, who have the authority to debit advisory fees from clients' custodial accounts, to undergo an annual surprise audit by an independent certified public accountant which can cost your firm between $8,000, and, in some cases, $25,000 per year.
lf you are an SEC registered investment adviser, and you believe that the SEC's position is unreasonable, we urge you to voice your concerns to the SEC and encourage you to write a letter on your letterhead and forward it to the SEC.
To find out more about this process go to: http://ncsonline.com/NCSOnline/News/tabid/195/newsID/54/Default.aspx
If you would like a "template" letter to use as a starting point please e-mail: ken@ncsonline.com subject line SEC Template Letter and we will be happy to send a copy to you.
Thank you,
Ken Kaltman
National Compliance Services, Inc.