Subject: File Number s7-09-09

July 16, 2009


Annual audit of RIA is not the solution. Confirmation of client assets held at a third party or broker/dealer firm is the issue. Audit and verify assets held at a "real" institution, like a UBS, DTC, State Street, Bank of NY, etc. and you have your solution.

This should be as easy as logging in and seeing assets.

The fraud players don't have assets at all.

This is not complex. Please do not take complex measures for simple issues.

I am happy to speak in person if needed.


Bill Boatwright, CFA, CFP
Vice President - Investments
Advisory & Brokerage Services
Wealth Advisor
Senior Portfolio Manager, Portfolio Management Program

UBS Financial Services, Inc.