Subject: 'File Number S7-09-09'

July 15, 2009

Good afternoon,

As a member of the Financial Planning Association of Massachusetts it has come to my attention that you are proposing surprise audits of Financial Planning firms such as mine.

I am a sole practitioner and someone who holds in high regard my ethics and values when dealing with clients. I am not however in a position to afford one of these surprise audits.

I would be forced in this situation to pass along these costs to my clients which would mean diminished returns to them. This is unacceptable to me as a professional advisor.

After 10 years in the broker-dealer world I wanted to hold myself to a higher standard of ethics and have a fiduciary relationship with my clients which is why I became a Registered Investment Advisor.

I do not in any way take custody of client assets and as such feel that my clients have a established method of protection.

Please do not establish the surprise audits.

Thank you,

Ted Wolfstich CFP
Wolfstich Capital Management, LLC