Subject: File No. S7-09-09
From: John H Vineyard, CFA
Affiliation: Sunlake Investment Management

July 28, 2009

After presiding over the Madoff disaster, by far the greatest regulatory failure in the history of our nation, the SEC finds itself in an awkward spot.

If our firm expanded 1,000 times over, then took all its clients' money, dumped it in a ditch, and burned every scrap, the total loss would be far less than the loss due to Madoff's actvities. Beyond all the losses of all of Madoff's clients, honest advisers and their clients have also suffered from the indirect fallout of that scandal. The Agency's response to its gargantuan dereliction is to say, "GIVE US MUCH MORE POWER."

Having reviewed the many cogent objections already made to the custody proposal S7-09-09, and considerable further deliberation, we are unable to see any reason that such a step is either logical, benefical, or desirable.