Subject: File Number S7-09-09

July 29, 2009

Dear SEC:

I am against the SECís plan to require audits of firms which have agreements to deduct client fees.

My accounts are all under custodianship at a major custodian Ė Charles Schwab.

There has not been abuse in this area. My clients agree in writing to have the fees deducted from their accounts. They see their accounts on the internet and get monthly and quarterly statements. They can move their accounts from my service on immediate notice if they are not satisfied. Do you think that Schwab is going into cahoots with me to defraud my clients?

Why donít you spend your time attacking the real problem Ė those firms that donít have separate custodianship? This is where the abuse is. You should audit and regulate these firms, not pile regulation and expense on those firms that arenít doing anything wrong.

Also, I suggest that you read your mail and follow up on tips.

Thank you,

Malcolm Clissold, CFA
SCC Capital Group, LLC
Brentwood, TN