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.

GLENN WOODY
FINANCIAL CONSULTANTS, INC.
Family Wealth Advisors