Subject: File Number S7-09-09

July 7, 2009

Iím writing to state my objection to proposed custody rule (lA-2876). This environment makes it difficult enough for those of us providing excellent service to individuals and who are neither operating illegally or unethically. We donít need the added cost and burden of an audit considering most of us have never acted improperly and would otherwise be assumed to be acting inappropriately. If you have any questions, I may be reached below.

All my best,

Bill

William L. Valentine IV, CFA
Valentine Ventures, LLC