Subject: File No. S7-09-09
From: Brian G Carney

July 1, 2009

I wanted to state my opposition to a surprise audit for firms that directly deduct fees from an independent custodian. More than 90% of our clients would rather have fees deducted from their investment accounts as opposed to being invoiced. Also, you certainly do not want to discourage any advisors to not use independent custodians considering the recent situations with Madoff and others.