Subject: S7-09-09

July 6, 2009

To Whom It May Concern:

The SEC already has in place laws that could protect client assets.

The victims of Madoff occurred because they chose to have their assets custody by Madoff and not a Third Party Custodian.
Rather than burdening small, fee-only Registered Investment Advisers with costly annual surprise audits; which would have to be passed on to the clients for the management of their accounts, perhaps the SEC should only allow custody of client assets by Third Party Independent Custodians.

Innocent Investment Advisers should not be punished because of the criminal acts of financial terrorist like Bernie Madoff.

Linda Sueing-Jackson