Subject: File No. S7-09-09
From: John Borger

July 1, 2009

There most certainly needs to be an exception for deducting quarterly fees from the custody rule.

There is quite a bit of redundancy. Advisors send out fee statements, the custodians show the deductions on the clients accounts, etc..

Not granting an exception would create unnecessary time and expense for surprise audits.

This rule goes too far for a problem that does not exist.