Subject: 'File Number S7-09-09'

July 3, 2009

I am a member of the FPS and a SEC registered Rep. I oppose this proposal. It is too costly and would be of little value in catching the bad guys. You guys don’t get it!!! The bad people don’t have the clients sign forms, disclosures, etc… Most of the “bad” guys aren’t even registered with the regulatory agencies.

Isn’t the SEC and FINRA, supposed to do surprise audits? Yes they do, the problem is they are understaffed and are forced to focus on the minor stuff like the size of fonts for disclaimers instead of if Madoff or Sanford are legitimate advisers.

I also think the following points are important to note.

If there is anything I can do to help, please do not hesitate to call me.


Robert “Puma” Richards Jr.
Masters of Science in Financial Services
Certified Financial Planner®
Certified Fund Specialist
Certified Annuity Specialist
Retirement Income Specialist
Board Certified in Mutual Funds
Registered Financial Consultant
EPA Financial Services, Corp.