Subject: File No. S7-09-09
From: Heather Rock

June 30, 2009

Dear Sirs,

I am a member of the Financial Planning association (FPA) and think that your idea of annual surprise audits is NOT a good idea. Please rescind. All the SEC needs to do to avoid scandals like Madoff is to correctly implement the rules already existing. Do not come up with new rules and new burdens, the cost of which ultimately get passed onto consumers. New requirements will also push more small, honest, investment firms out of the business and concentrate power in the hands of a few large firms – which from the current financial “too big to fail” crisis we have already seen that we need more diversification in the financial arena, not less.

Thank you,

Heather Rock