Preliminary Request for Public Comment on Proposed Fee Table for State-Registered Investment Advisers

February 16, 2018 - Andrew Simms

Subject: Proposed Fee Table: Public Comment
From: Andrew Simms
February 16, 2018

Good Afternoon,

Although the proposed new fee table unfortunately increases the regulatory burned, and clearly adds to the already time consuming and expensive regulatory requirements, I do believe it is a good idea to implement for large investment advisers with complex fee arrangements.

On the other hand, I do not believe the proposed fee table is a good idea for hourly rate advisers, sole proprietors, small businesses, and all advisers with a basic fee structure. I would please request that a waiver be available for advisers with those business characteristics. For small advisers each additional piece of regulatory work takes away from time spent offering advisory services and directly negatively impacts the finances of the business.

Best Regards,
Andrew Simms

Owner & Chief Compliance Officer
Principal Management and Research, Co.