Subject: File No. S7-09-09
From: Jeffrey Feldman, Ph.D., CFP
Affiliation: Registered Investment Advisor

May 22, 2009

In regards to the proposed SEC rules changes concerning advisor billing (and required accountant audits), I feel strongly that advisors should not be able to automatically deduct fees from client accounts. For the 16 years that I have been in business, I have always had clients approve each bill by signing my invoice letter and then forwarding the letter to the custodian (Schwab in my case). When clients complete new account application forms, I don't have them initial the line that gives me fee disbursement authority. This fee arrangement should prevent any advisor abuse of client funds.