Subject: 'File Number S7-09-09'

To Whom It May Concern:

I run a 3 person office and the cost of an annual surprise audit will be prohibitive.

Even a planned audit is very expensive for a small business.

Please find a more workable alternative such as an audit every 5 years or perhaps a compliance audit by an independent firm such as National Regulatory Services.


Vivian Holzer
Holzer & Company, Inc.