Subject: File Number S7-09-09

July 15, 2009

I am solidly against this knee-jerk proposal undoubtedly launched as a "solution" to the "Bernie Madoffs" in the investment industry. Adding yet another billion dollar regulatory burden in an already heavily regulated industry is economically inefficient and very likely non-productive in identifying frauds like Madoff's and Stanford's. There just aren't that many fraudsters in the business that would be caught by surprise annual audits versus simply heightened diligence during routine examinations.