Subject: File Number S7-09-09

July 16, 2009

Dear SEC,

I would like to submit comments in regards to the recent proposal by the SEC to have investment managers audited by independent accountants where they have authority to withdraw advisory fees from client accounts. I think the benefit of this measure far outweighs the cost. I think this cost implementing these audits will be prohibitive, especially for smaller investment managers like myself.

I think a more prudent approach would be to include this as part of the process when the SEC audits investment managers. I think the SEC could take a sampling of accounts to ensure that fees are being charged properly. In lieu of making the environment more regulatory, I think the process is there it just needs to be implemented during regular audits.

Respectfully Yours,

Anthony J. Abbate
Managing Director
Granite Value Capital, LLC