Subject: File Number S7-09-09/ - opposed

July 23, 2009

We FPA members are opposed the proposal to have paid surprise audits.

The smells like a political move to appease those who point fingers at the SEC for letting Madoff get away with his crime for so long. The SEC should hold FINRA accountable.

In order to enhance consumer protection I would support Congress funding the SEC to hire and train additional staff to do regular audits of investment advisers.

Also the SEC already resolved the custody loophole Madoff's CPA's used to avoid detection.

Brett Schwartz