Subject: Please vote NO to proposed custody rule (lA-2876)

July 8, 2009

We are all for safety and SEC regulation of RIAs who also act as custodians, but believe that the proposed Rule change (lA-2876) is unnecessary and unreasonable since it imposes an unjustified financial burden on SEC registered advisers who are not custodians but would be subject to the proposed Rule change.

The proposed custody rule (lA-2876) - hnp://wvrrw.sec.sov/rules/proposed.shtml would subject SEC registered investment advisers, who have the authority to debit advisory fees from clients' custodial accounts, to undergo an annual surprise audit by an independent certified public accountant. Depending on the type and number of advisory accounts, the cost of such an audit could easily exceed $8,000, and, in some cases, $25,000 per year.

Please vote NO to proposed custody rule (lA-2876) and find another way to regulate the safety of the custodian.

Thank you,


David S. Thomas Jr., CIMA
Chief Executive Officer
Capital Advisors LLC