Subject: File No. S7-09-09
From: Dennis M. Strasser, CFP

June 30, 2009

I strongly object to the SEC requirement that RIA firms be subjected to annual audits costing on average $8,100. This is a huge expense for any small firm. Less money spent on equipment and employment of new staff. While I strongly believe that an RIA firm should comply with any and all compliance this new requirement under consideration would waste valuable resources which could be used to adequately audit the large firms.

Taking the leap that being able to deduct fees from client accounts constitutes custody is ridiculous. The reason we have broker-dealers BD is so that an arms length arrangement can be maintained between the RIA and BD. This certainly could have helped in the Madoff case. While there needs to be changes to some regulations, it would make sense to spend time and money to enforce the regs currently on the books. This would have avoided the Madoff case.

While you will probably succeed in reducing the number of RIAs, you will certainly increase the number of public accountants.