Subject: File Number S7-09-09

July 1, 2009

To Whom It May Concern,

As the CCO federally regulated IA who has custody of assets due to the direct deduction of fees, I would have to object the rule requiring a surprise audit if the funds are held at a qualified custodian. I would be in favor of more disclosure to clients and or more rules regarding limitations on direct deductions, but the extra financial burden due to a surprise audit would be severely detrimental to our business.


Peter W. Raber
Vice - President
Aldebaran Financial Inc