Subject: File Number S7-09-09

July 14, 2009

Madden Securities Corporation, a registered broker/dealer, and a registered investment advisor, is strongly opposed to the specific requirement of a surprise audit annually by an independent accounting firm.

It now seems the regulators (or the elected officials) are over-reacting to a series of past inadequate examinations, and internal controls, that have recently come to light due to the Madoff and Stanford schemes of defrauding investors. Those of us that make every effort to abide by the regulations, and have done so for nearly 50 years are being asked to undergo this surprise audit at OUR expense. This entire rule proposal is over-reaching and burdensome from a manpower and cost perspective!

Perhaps some consideration should be given to recalling just how effective the past regulatory environment was conducted when the “self-regulatory” approach prevailed back in the periods of the 60’s, 70’s, and early 80’s. If anyone would like to discuss the effectiveness of this approach to regulation during these years (and probably before), I will be glad to offer up my views.

But, please DO NOT IMPOSE additional regulatory expense on this industry, as we have increased our current budget requirements for compliance almost three-fold in the past several years, in reaction to some very bad apples in the barrel.

If I can be of additional help, and provide any insights, please feel free to contact.

Respectfully submitted;

William B. Madden

Madden Securities Corporation