Subject: File No. S7-09-09
From: Eric J Robbins

July 6, 2009

As a small independent advisor, this proposed rule change would materially and adversely affect my business. Deeming every account where fees are directly debited as "custodied" assets with the requisite costly independent audit would impose an unfare cost burden on small businesses many of whom are opperating honerably. This oversight should be managed in the routine surprise SEC audits.