Subject: File Number S7-09-09

July 14, 2009

Dear Sir or Madam:
Please be advised that if 'File Number S7-09-09' goes into effect it will place a tremendous strain on the small advisor. By being able to directly debit fees out of a client account has never been considered custody in the past and the vast majority of advisors do not abuse this privilege.
Thank you.

Peter Salzman CPA, CFP