Subject: File No. S7-09-09
From: Ronald M. Robins
Affiliation: Beacon Financial Advisors, Inc.

June 30, 2009

This is an absurb rule that will do nothing but increase the cost of operating an RIA and provide little or no benefit. In particular, it will contribute to overwhelming smaller RIA's who can't pass these costs on to clients.

In addition, these auditors have shown repeatedly that are incapable uncovering anything. Their focus is always rules based and results in lots of paperwork and re-working of forms with no substance to assure a rule is followed. Madoff followed every rule perfectly and no one ever found anything wrong.

Ronald M. Robins
Beacon Financial Advisors, Inc.