Oct. 26, 2022
October 26, 2022 We are a North Carolina-regulated RIA and NC follows SEC rules. It appears the drafters of this proposed rule have no idea how burdensome and prescriptive it is. It's 232 pages long. If you can't explain it in a page, please try again. We rely on Envestnet and we have zero leverage over how they operate so we can either hire them as they are or go looking for someone else. If this rule is adopted, firms like ours are simply going to ask providers for their equivalent of a SOC 1 report. We will be TOTALLY relying on their representations for our due diligence. If the rule disallows this, then the SEC will be creating an entire new industry of 3rd-party evaluators and we will be relying upon them. So what's the point? We agree with Commissioner Peirce and ask what problem is this proposal trying to fix? We do not need new rules to hold us accountable to our clients or regulators