Subject: proposed custody rule IA-2876 S7-09-09

July 7, 2009

In regard to the proposed custody rule IA-2876, we think the requirement for an annual surprise independent audit creates an unnecessary burden on SEC registered advisers that only have custody for purposes of authorized fee deduction from independent qualified custodians. Since all investment costs eventually get passed on to the investor, we think there must be a more cost effective way of addressing this issue - especially for small firms that utilize only independent qualified custodians.

Michael J. Norris
Valued Investment Partners, LLC