Subject: 'File Number S7-09-09'

July 9, 2009

While I am strongly supportive of the need to strengthen investor protection in light of the Madoff scandal and other Ponzi schemes, I agree with the FPA, that the best approach is to give the SEC the resources it needs to audit advisory firms, not outsource that responsibility. In addition, the approach taken by the SEC in this rule is directed at a problem that does not exist, which is also in agreement with the FPA.

Leonard J. Klucar, CFP