What criteria should be included in the rule to determine whether a third-party compliance expert is independent?
FPA strongly believes that the third party compliance vendor must be an unbiased, independent party to be qualified to audit investment adviser firms. For that reason, FPA would strongly oppose a self-regulatory organization whose membership and governance structure is made up primarily of sales-oriented firms. Any compliance vendor should be unaffiliated with and completely independent of the financial services industry and the investment products and associated sales records the compliance firm would audit. The potential problems here are analogous to those issues that led to major changes in auditing and corporate governance last year regarding a corporate auditor’s conflicts of interest. b. Self-Regulatory Organizations. FPA opposes an SRO for registered investment advisers; suggests feasibility study of PRO as alternative for financial planning profession. The question of an SRO for investment advisers, and in the past two decades for financial planners, has been debated intermitt
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