Subject: File No. S7-09-09

July 17, 2009

As an FPA member and investment advisory representative of an SEC-registered investment adviser, I am writing to comment on the proposed changes to the Custody Rule, Release IA-2827 and to state my strong opposition to this rule change as unnecessary, overly burdensome and costly for the small practitioner, and unlikely to improve the protection provided the public.

However, In order to enhance consumer protection, I would support Congress appropriating additional resources to the SEC to hire and train additional examination staff to increase the regular audit cycle of investment advisers.

A. Raymond Benton, CFP, CRPC, EA*
Member of President's Cabinet
Premier Partner
Member Private Wealth Management
Lincoln Financial Advisors