Subject: File #S7-09-09

July 2, 2009

Consideration of this change is onerous and only adds to the buracratic jumble we, as Investment Advisors already face. I deduct fees from my client accounts only after they have signed and approved me doing so. Secondly, the client is informed of the fees when taken. Third, the State Securites division of Washington checks these proceedures during their audits. We do not need further oversight!

Sincerely,

Gary Finke
Investment Advisor
State of Washington