Subject: File No. S7-09-09
From: A. J."Sandy" Stuart, III, CPA
Affiliation: Huff, Stuart & Carlton

June 19, 2009

Recommend that the SEC require independent custody of all client assets, that the independent custodian be required to send statements independently to clients and that all deducted fees be disclosed to the client in these statements. These requirements should provide necessary and effective disclosure and transparency to the client when fees have been transferred as payment from their account to that of a servicing registered investment advisor.

A. J."Sandy" Stuart, III, CPA
Investment Advisor
Huff, Stuart & Carlton