Subject: File No. S7-09-09
From: G.M. "Buz" Livingston III

June 30, 2009

We strongly disapprove of the SEC's proposal to define "discretionary" control as the ability to deduct fees.

Any fees that are deducted are disclosed in advance and the client must approve.

This is a burdensome regulation that will not benefit the public one iota.

Sincerely yours,

G.M. Livingston III (Buz)