Subject: File number S7-09-09

July 2, 2009

SUBJECT: File No. S7-09-09

FROM: Jackie Karnavas

AFFLILIATION: Torrey Capital Investments

To whom it may concern:

I am associated with an RIA and I am against the proposed rule for the “surprise” audits for the RIA’s who automatically deduct fees from clients accounts. These audits would not only be time consuming but very costly to smaller firms; a cost that would be passed on to clients. The recent ponzi schemes by Madoff, had nothing to do with the fees or the way the fees were deducted from the clients accounts. Madoff took physical custody of his client’s accounts, which is a much different platform then using a independent third party custodian.

Jackie Karnavas