Subject: File No. S7-09-09

July 2, 2009

As a small independent financial planner, the additional burden of a surprise audit requirement will add costs to my business that will be passed on to clients.

The Madoff fraud had nothing to do with fees deducted by investment advisors. The regulations already in place should have been sufficient to identify the fraud if the regulators had been paying attention.

Additional regulations only add to the burden of small investment advisors, which ultimately will cause them to cease providing services to small investors. There needs to be a threshhold which identifies tiers for additional regulations, based on assets under management.

Thank You,

Bertram H. Rosen, CFP