Subject: 'File Number S7-09-09' in the subject line.

July 7, 2009

It seems like the SEC is considering making a rule as a reaction to the Madoff situation that would cost thousands of dollars and waste thousands of hours of hard working honest, ethical investment advisors time. Maybe it would be prudent for the SEC to really go after with scrutiny those they have been warned about over and over, for instance Madoff, where they are suspected to be running shady operations.

It is also not necessarily custody when an investment advisor manages on discretion and takes a fee out of the account. You had a situation with Madoff, where if I am not mistaken, was his on BD and his own clearing firm. Most RIA’s have at least one level of removal from their clients money. Big difference.

Respectfully submitted,

Sonja White, CLU, ChFC
Fortune Financial Services, LLC