Subject: Auditing of RIA firms regarding custody of client funds s7-09-09

July 27, 2009

My firm is an SEC registered RIA firm with client accounts held in custody at Fidelity and Schwab. We do not hold client funds which can be confirmed by regular SEC audits. I welcome those audits. It should be unnecessary and costly for surprise audits, especially since our firm does not hold client assets directly. Thank you for your consideration.
David Witherbee
David Witherbee and Associates, Inc.