Subject: File No. S7-09-09
From: Rich Arzaga
Affiliation: Founder and CEO, Cornerstone Wealth Management

June 30, 2009

Please accept my feedback to this effort. I am a FPA member and SEC-registered investment adviser. I am opposed to the requirement in the proposed amendments to the custody rule that would subject investment advisers to a surprise audit by an accounting firm. My reasons:

But I think it is a terrible waste of money, time, and resources to regulate advisors who custodian assets and are still subject to this unnecessary oversight because the fee is collected by the custodian on behalf of the advisor. Makes absolutely no sense, and is a gross over-reach of what you are trying to accomplish. More regulation is not smart; smart regulation is smart. No on subjecting advisors who collect a fee but donít custodian of File Number S7-09-09.

Thank you.