Subject: 'File Number S7-09-09'

July 22, 2009

I am concerned about this rule. I think it is unnecessary for most advisors, this will generate more costs that will ultimately be borne by the client. Further, this has never been an issue in the past. This area is already covered under the SEC when advisors are audited and I have not heard of any abuse in this area.

V. Peter Traphagen Jr. CPA, PFS
Traphagen Financial Group
Traphagen Investments Advisors, LLC