Subject: File Number S7-09-09

July 9, 2009


I am opposed to the proposed rule requiring a surprise audit of Investment Advisors who deduct fees from client accounts. This is a very costly proposal which will provide practically no additional protection to investors. It will most certainly not catch the next Madoff ponzi scheme as any such perpetrator will surely find some way around the protection through a fake or corrupt audit. All the proposed rule will do is increase the cost for the honest investment advisors and their clients with little benefit to those clients.

I support the Financial Planning Association’s (FPA) response to the proposed rule. Certainly as a minimum, investment advisors who simply charge their advisory fee directly to client accounts should be exempted from the audit requirement.

Thank you for the opportunity to comment.

Parker Consaul CFA®