Subject: File No. S7-09-09
From: Leora Garner
Affiliation: President, Laurel Grove Capital, LLC

August 7, 2009

Dear Elizabeth Murphy:

I am writing to ask you not to pursue the idea of having investment managers who take their fees out of client accounts be considered as having custody. We always send a copy of the amount withdrawn and we NEVER take anything else out. the fee withdrawal is specifically approved by the client in writing. If we have to be audited, this will cost our company thousands of dollars that we can ill afford. It is unfair as it will precipitate our needing to close our business and our six employees will join the ranks of the unemployed. With health insurance costs climbing, this will be the last straw. We cannot afford this in addition to the taxes-federal and State.

And by the way, while Enron imploded and Madoff "made off" with clients money, our firm was being audited by the SEC. In fact, for some inscrutable reason we have been audited three times in the 12 years we have been in business. I know of no other firm to have been audited so many times. And they never found anything substantial, I might add.

Thank you for your time. I trust you will think long and hard before implementing this proposed custody rule.

Leora Garner
Laurel Grove Capital, LLC
Los Angeles, CA