Subject: File No. S7-09-09
From: Tim A. Konicke

June 30, 2009

I strongly oppose the proposal for surprise audits for registered investment advisory that have client fees withdrawn from client accounts. In addition to the client agreeing upfront to have fees deducted from their account, our clients are sent a paid invoice/notice that the fee has been withdrawn each time it is withdrawn. They also see this fee deduction appear on their monthly statement. Therefore, there is full disclosure upfront and on an ongoing basis of these fees. I feel this is a waste of time and money.

Tim A. Konicke