Subject: "File No. S7-09-09"

July 15, 2009

Dear SEC:

I'm a small Advisory Firm with $40m under management. I STRONGLY OPPOSE your proposal to have an independent audit on my advisory fees conducted by a CPA. This requirement is extremely harmful, expensive and misguided. As a small SEC registered firm, you would force me to raise fees and spend less time managing client assets.THIS IS AN EXTREMELY BAD IDEA!


Brian Carruthers, CFP,CMT
Brian Carruthers & Associates