Subject: I am against the proposed rule changes s7-09-09

July 14, 2009

Dear SEC

I am against the proposed SEC rule proposing annual audits by CPA firms of investment advisers deducting investment advisory fees. My primary reason is the Ponzi schemes uncovered by the SEC had nothing to do with fees deducted by investment advisers. As far as we are aware, there have been no systemic problems in this area and this proposal is unnecessary, costly and burdensome, particularly for small, independent investment advisers. In order to enhance consumer protection, I would support Congress appropriating additional resources to the SEC to hire and train additional examination staff to increase the regular audit cycle of investment advisers.

Fred Murphy

Fred E. Murphy, IV, CFA
Murphy, Middleton, Hinkle & Parker