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

July 7, 2009

I do strongly oppose your proposal for Surprise Audits of Discretionary Accounts.

I understand your need to regulate this industry; however, you have all the regulations you need now to do the job.

You need just to implement the tools already at your disposal without adding more.

Why make us suffer for your inability to do Your Job. Madoff, Sanford and the likes could have been discovered much earlier had you only exercised the rules and regulations and audits presently available to you.

Besides listening to and responding to the whistleblowers.

Yours truly,

Sue Harford Ferdig, CFP, CRPC, CFEd
Accredited Wealth Management Advisor