Subject: surprise audit s7-09-09

July 1, 2009

There is no one who knows more than the SEC on whether RIAs have been correctly debiting fees from the clients accounts over time. If there has been numerous irregularities,it is good to implement the rule of having surprise audits.If there have been no or little irregularities the added cost of surprise audit makes insignificant improvement for the industry. Punishing law biding RIA's because of Bernie Madoff is not fair ; building another layer of bureaucracy and creating a time consuming endeavor for political reasons instead of practical reasons is simply the wrong action by the Commission.I would suggest that the SEC does not act in haste on this matter unless it is a serious problem.


Samson Wang
Runnymede Capital Management, Inc.