Subject: File No. S7-09-09
From: George N. Luciani, CFP
Affiliation: Capital Planning Advisory Group, Inc.

June 30, 2009

Your proposal to have accountants automatically audit discretionary advisors accounts at a fee of $8,000/year is onerous and unnecessary, especially for small firms.

The SEC is covering up their own inefficiencies with this unnecessary step that protects no one. Madoff cleared his own phantom trades; that was the problem. We do not need this legislation.

George N. Luciani, CFP