Subject: File No. S7-09-09
From: Craig A Cook
Affiliation: President, Oakbrook Solutions, Inc.

July 28, 2009

1) Custody capacity - There is a tremendous amount of custody capacity available to RIA's of all sizes. These services are avaialable from banks, brokers, and institutions of all sizes. Given this, I would think that requiring RIA's to use a qualified independent custodian is the most efficient route vs. building a tremendous amount of exceptions to cover RIA's who want to do custody for themselves. By it's nature custody does not offer the RIA any differentiation in the market - why would you want to do it?

2)The Big Three - There are 3 major players that gather the majority of the assets in the RIA space, Fidelity, Schwab and BoNY Pershing. These firms bundle custody services with advisor tools to create a total platform. As such the true price of custody services to wrapped into the total price for their services. For RIA's who don't need or want the tools that these 3 offer there are not a lot of alternatives that are practical.

3) Custody network - The best case scenario would be to build a custody network that RIA's could utilize similar to DTCC. There is an added benefit to their business for this type of network - data aggregation. Meaning they could get information on other client assets from the network so they could accomplish effective financial planning.

Conclusion: My recommendation is that RIA's must use a qualified independent custodian going forward. The environment that exists will need to be upgraded technologically to facilitate efficiency (which will drive cost down) and data aggregation.