Subject: File No. S7-08-09
From: Philip brux
Affiliation: CPA

May 14, 2009

These are good ideas.

The best idea yet, however, is one that I have proposed, and suggested infinitum to previous SEC commissioners and our state securities regulator, and it is...

Finally, you are suggesting SURPRISE AUDITS. WHAT TOOK YOU SO LONG

All rules are made to get around, according to many people.

From experience, there is nothing like surprise audits to keep more people honest.

Just the surprise alone would have caught Madoff a long time ago. He would not have been able to keep the bezzle going as long as he did.

Phil Brux