Subject: File Number S7-09-09

July 15, 2009

I am a member of the FPA of Massachusetts and am an IA under the RIA of our firm. I am opposed to the proposed changes to the custody rules that would expose IAs to surprise audits by accounting firms, to be paid by the adviser. The current rules, as recently amended, are more than sufficient if properly enforced. I doubt very much that the change would be an effective way of catching any frauds similar to Madoff’s – or any other similar scheme at whatever scale. There would be a real cost to small businesses and a serious disruption to services to the public. Please concentrate your efforts on properly staffing, training, and using SEC personnel. Thank you.

F. Richard Bowen, ChFC

The Bowen & deNapoli Group
At Winslow Evans & Crocker, Inc.