Subject: File number S7-09-09

July 6, 2009

I am a FPA Member and SEC registered investment adviser based in New Orleans, LA. I am strongly opposed to the requirement in the proposed amendments to the custody rule that would subject investment advisers to a surprise audit by an accounting firm.

The SEC has already resolved one of the major problems with the custody rules which eliminated the Madoff loophole. This regulation seems to be more of a political reaction than anything that will actually improve supervision for investors. This surprise audit requirement will add additional costs to our business that will ultimately be borne by clients and not by firms. We would encourage congress to appropriate additional resources to hire and train additional examination staff to increase the regular audit cycle of investment advisers which would be more impactful than this proposed regulation.


H. Jude Boudreaux, CFP(r)
Director of Financial Planning
Bellingrath Wealth Management