Subject: S7-09-09 Comments

July 13, 2009

I'm an FPA member, a NAPFA member, a CFP(R) and an SEC Registered Investment Advisor. I have 14 years of experience. I do NOT take any custody of client assets, all assets are held at client directed custodians. Having to bear the cost of an audit would cause me a severe financial hardship as the recession and economy have already knocked my business back to ground zero.

Please consider carefully the impact this measure will have on small RIA's like me who are PURELY FEE-ONLY, take no commissions, Do NOT accept client assets and take no custody of client assets. We should be exempt from this measure due to the nature of our practice. As a one man operation this could potentially put me out of business if I were forced to pay for an audit - I'm already on a shoestring budget and having to devote the time and money to go through an audit would be severely detrimental to my ability to serve my clients needs.


Greg Phelps