Subject: Surprise Audits of RIA Firms s7-09-09

July 6, 2009

I am a member of the Financial Planning Association and am an SEC Registered Investment Advisor.

I am strongly opposed to the proposed rule requiring surprise audits of RIA firms simply due to our deducting our fees from a client's account.

I am as sickened as anyone by the actions of Madoff and other ponzi scheme operators and encourage increased regulation and oversight to thwart such schemes in the future. But, the deduction of a fee from a client's account did not contribute to those schemes at all. The idea of imposing the suggested surprise audits is a typical political over-reaction. It is totally unnecessary and will be costly in terms of a dollar cost and the time required to comply. Both such costs will result in increased costs to our clients and a dilution of our service to them.

Attack the problem, but do it directly to the source of the problem, not in this fashion.

Family Wealth Advisors