According to the survey, a full "enhanced SEC" examination program is projected to cost US$240-270 million per year. In contrast, a FINRA-IA SRO (examination, enforcement, and SEC oversight) is projected to cost US$540-610 million per year; and a New-IA SRO is projected to cost US$610-670 million per year.
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The survey also says that funding an SRO would likely cost investment advisors at least twice as much as paying user fees to the SEC.
The average annual fee per IA firm is projected to be $27,300 for a full "Enhanced SEC" examination program; $51,700 for a FINRA-IA SRO; and $57,400 for a New-IA SRO.
BCG also conducted an online survey to understand the preferences of investment advisor and for that it received 424 responses.
According to the survey, more than 80% of investment advisors preferred the SEC over a FINRA (based on SEC user fees that were about 24% lower than FINRA membership fees).
The survey also said that 75% of investment advisors prefer a new-investment advisor (IA) SRO over a FINRA-IA SRO even if this option would cost advisors 20% more.
And the preference for a new-IA SRO remained strong even given increasingly higher costs.
The survey was conducted in response to calls for additional analysis of the recommendations in the SEC’s study under Section 914 of the Dodd-Frank Wall Street Reform and Consumer Protection Act.
The study was commissioned by Certified Financial Planner Board of Standards (CFP Board), the Financial Planning Association (FPA), the Investment Adviser Association (IAA), the National Association of Personal Financial Advisors (NAPFA), and TD Ameritrade Institutional.
