Subject: File No. S7-09-09
From: Alvin H. Miller, Jr.
Affiliation: Investment Officer, James River Asset Management, LLC.

July 1, 2009

The proposed rule change would be burdensome and potentially expensive, particularly for smaller advisors. Our clients receive two separate notices for fee deductions, which are both quite transparent. To say we have custody of assets which we can only access via twice disclosed invoices makes a mockery of the terms custody and common sense.