Subject: File No. S7-09-09
From: Ricardo Ulivi
Affiliation: NAPFA

May 22, 2009


Your proposed rule regarding the payment of surprise audits will unreasonable affect "solo" practitioners. Personally, I generate about $80,000 in annual fees and my profit is less than 10% of that. Requiring me to pay for surprise audits will bankrupt my business. This will negatively affect my clients because I will no longer be able to serve them.

The convenience of automatic deduction of fees is great. Mutual fund companies are allowed to report NAV's net of fees and they are allowed to deduct fees. Why can't we independent advisors keep the same authority.

There are thousands of small solo advisers you do not need additional red tape to collect our fees. The current system works very well so why change it?

Thank you.