Subject: File No. S7-09-09
From: john r goodrich
Affiliation: CFP

August 5, 2009


I am writing to express my views on the proposed rule 206(4)-2 concerning custody rule. I am a small RIA with couple dozen accounts where I am personal friends with each client. The proposed rule change I believe is over kill for my practice as well as many others in similar size and even larger. Small business is burdened enough with regulatory requirements and I believe this change will serve of very little security for clients but yet disproportionably add expenses to the RIA firm. I believe this is overkill and should not be considered in it's current proposed form.

Thank you.

John Goodrich

Goodrich Financial Group, llc
16835 W. Bernardo Dr., Suite 202
San Diego, CA 92127