Subject: File No. S7-09-09
From: Robert J Reed, Jr
Affiliation: FPA, NAPFA

June 1, 2009

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I recommend that the SEC simply require independent custody of all client assets, that the independent custodian be required to send statements independently to clients,and that all deducted fees be disclosed to the client.

The SEC can adequately monitor broker/dealer custodians' for compliance.