Subject: File No. S7-09-09
From: Kirk B Young
Affiliation: Managing Member - BARR Financial Services, LLC

June 22, 2009

I will try to be short with my comments. The proposed bill, Rule 206(4)-2 would create an enormous burden on small firms. I understand the need to protect the public, but here has to be a better way. To pass such a large cost to firms like ours that are small and serve our clients is not needed. An audit by the SEC every two years would accomplish what is needed. The SEC is to be a regalatory entity and should do this without passing the costs on to small firms that follow all the rules.