Subject: File Numbers S7-09-09

July 1, 2009

Ref. File Numbers S7-09-09

I strongly oppose the proposal for surprise audits for registered investment advisory firms that have client fees withdrawn from client accounts. In addition to the client agreeing upfront to have fees deducted from their account, our clients are sent an invoice/notice that the fee will be withdraw. They also see this fee deduction appear on their monthly statements and it is monitored by the custodian, TD Ameritrade. Therefore, there is full disclosure upfront and on an ongoing basis of these fees. I feel this is a waste of time and money.
Best regards,
Barry J. Swaim, CFP(tm)