Subject: File No. S7-09-09
From: Sammy D Tally, CFP
Affiliation: CCO

July 28, 2009

I do not believe that if RIA fees has a proper fee agreement with the client that it constitutes client custody, since the fee is by contract with the client not at the IA's dicretion.
Thank you for your considerations.
Sammy D. Tally, CFP, CCO