Subject: File No. S7-09-09
From: Mark Wallace CFP CRPC
Affiliation: Bay City Financial Services, Inc.

June 30, 2009

As a small, locally owned Registered Investment Advisor, the proposed rule would hurt us and our clients. We directly debit management fees from client accounts to avoid paper billing and trying to collect our compensation from hundreds of people. If subject to expensive audits, our costs would skyrocket and our clients would be subject to additional costs and headaches. I dont mind the rule so much, but there should be an exception for directly debiting management fees.