Subject: File No. S7-09-09
From: Antoinette Laferriere, CFP

July 15, 2009

I believe the proposed annual surprise audit is excessive and unnecessary for RIA's with 3rd party custodians. The ability to withdraw fees from client's accounts does not put the public at sufficient risk to warrent this extreme measure.

For RIA's who custody client's assets without a third party, I agree that surprise audits are warrented.