Subject: File #S7-09-09

July 6, 2009

To Whom It May Concern:

I just recently read of the SECís proposed changes to the custody rule under the Investment Advisers Act of 1940, Rule 206(4)-2. The proposed custody rule (IA-2876) is an overreaction to the high profile scandals that have rocked the financial industry over the past several years. If passed, this new rule would be an extremely expensive and an ineffective way to police the industry. There are more effective ways for the SEC, during routine and surprise (for cause) audits, to regulate and police the RIA world. Please note my strong opposition to your proposal.

Sincerely,

Jeff Powell