Subject: custody s7-09-09

July 23, 2009

My name is Georgia Bruggeman and I am a CFP, Registered Investment Advisor running an independent financial planning and asset management firm. I am a member of the FPA, NAPFA, CFA Institute.

I just want to point out that my independent custodian, TD Ameritrade already closely monitors the fees I charge my clients. Every quarter they review all the fees submitted for my clients relative to the size of their account. If they notice a fee that appears to be too high they will call me and want an explanation. The explanation is always that it is a one time annual charge. I am a small fee only advisor. I do not sell products or receive compensation from anything I recommend. It will be extremely onerous for me to have a surprise audit that could cost me over $10,000. That would be almost 10% of my gross income! WE already provide our clients with fee statements and they see on their monthly custodian statements the fees that have been deducted. This audit fee would be my biggest expense. Please reconsider this proposal.

Sincerley, Georgia Bruggeman