Subject: s7-09-09

July 16, 2009

I totally disagree with this rule change proposal. Rules already in place provide the consumer protections sought. Further, these rule changes will cost consumers much more in advisory fees with no increase in service or safety. Deductions for fees are almost universally done by third party custodians. I oppose this rule in the strongest possible way.

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Michael L Shipman
"Shipman & Associates, LP"