Subject: File No. S7-09-09
From: Mark L Kornblau, CFP
Affiliation: Financial Design Management, Inc.

July 23, 2009

One additional comment regarding this proposed rule as it affects advisors who have independent custodians.

Despite my having many good friends who are CPA's, based on Enron, Worldcom, FNMA, etc, etc, ad nauseum, will CPA's really be able to do what you propose during their audits for ONLY $8,000 per advisor per year? History suggests otherwise.