Subject: File No. S7-09-09
From: Brant J Donis
Affiliation: Financial Planning Association

June 21, 2009

It is my sincere hope the proposed regulations regarding "surprise audits" for investment advisors with custody of client assets be allowed to die quietly. Such a cost, estimated at over $8,000 a year is simply an expense my recently opened small firm could never hope to afford, and would serve only to strike a lethal blow against the American small business owner, like myself, while making larger firms the only choice for the consumer. The SEC would be better advised to focus its attention on the entire commission structure of all financially-related companies, which is at the root of the problems endemic in American capitalism. By mandating a compensation structure based on business profitability and not on volume, the American consumer, employee and investor would profit from a suddenly-aligned goal, spurring new levels of productivity and engaging our workforce in the most positive way.

I welcome questions about my statements, and feel passing these regulations would be in the worst interest of the American consumer, even though I currently do not even offer these services to my clients.

Brant Donis
Founding Principal
Landmark Financial Planning, LLC