Subject: File No. S7-09-09
From: Janet Tyler Johnson, CFP®, RFC®
Affiliation: President, JATAJ Wealth Management, LLC

June 30, 2009

With all due respect I wish to strongly disagree with the above referenced proposed legislation. Although I own a state regulated RIA, I have managed federal registered RIAs and feel that this proposed legislation will impose undue costs to the average RIA while offering little protection to the clients IF there is a third party custodian in the picture.

Obviously if there is no third party custodian, that is a totally different story, but clients who have their assets custodied by a third party independent custodian (Schwab, Fidelity, TD Ameritrade, etc.) get independent reporting on a monthly basis so that they can confirm that they are not getting more deducted from their accounts than disclosed in their Engagement Agreement.

I strongly feel that when new legislation is proposed, whether or not a client’s assets are custodied at an independent third party custodian should be taken into consideration.

Thank you.


Janet Tyler Johnson, CFP®, RFC®
Author of Finding Financial Fulfillment
JATAJ Wealth Management, LLC * JATAJ Life Planning, LLC * JATAJ Wealth Advisors Network, LLC