Subject: File No. S7-09-09
From: marvin s heiman
Affiliation: RIA

December 23, 2009

We manage under $30 million through Charles Schwab and Company. We do have the approval to deduct client's fees from Chas. Schwab with the written approval of our clients.
A burden as suggested of close to $8000 or more for independent accountants would be so costly that it would not pay for us to stay in business under those circumstances. We hold no clients assets and if the only reason that the new custody rules would aplly is the payment of our fees from the clients accounts at Schwab then at least we would stop that practice and bill our clients directly.

marvin heiman for Sussex Financial Group, Inc.