Subject: File No. S7-09-09
From: Jon D. Walton CFP CLU

June 30, 2009

This proposed regulation is classic overkill in light of the likes of Bernie Madoff. The fact that I earn feeís on assets under management does not constitute custody in any way. Quite the opposite. I donít even have discretion over the accounts. A third party has discretion and I receive Solicitors fees. Even the third party can only withdraw money and have it sent to the clients checking account, Wire or address of record. Plenty of checks and balances in force already to stop the honesty people from becoming dishonest. You canít stop the criminal mind by over killing the honest majority. Stop the nonsense and improve the regulation of those able to enter this business and stay in this business. Jon in Delaware

Jon D. Walton CFP CLU
726 Yorklyn Rd suite 300
Hockessin De 19707