Subject: File #S7-09-09

July 3, 2009

I am a small solo Fee Only Financial Planner.
The proposed rule concerning custody and surprise audits would devastate my firm. I deduct fees in the amount of 0.25% or less per quarter and I custody at Ameritrade and follow all the rules. They suspend the deduction if it is more than 3% of an account.
This rule is totally unnecessary and is a knee jerk reaction to the actions of one crook. If his money had been at Ameritrade, he would not have been able to pull off the fraud. Please, do not destroy the Financial Planning Business on a knee jerk.

G. Douglas Dunham CFP
Dunham & Associates Financial Planning LLC