Subject: File No. S7-09-09
From: Alvin Gebhart

June 30, 2009

I do believe that reviewing an investment advisor is required, but using this rule is wrong. The deduction of fees is a method for which advisors can obtain their fees and continue working without a billing issue. This process prevents and helps because otherwise we would have to mail and wait for the fees and get into a account receiveable position and then if the client was slow in paying then what. Would the advisor then consider not working as hard and why should they or not at all if the account was past due for an extended period of time. Then what other regulation would be fall the advisor. The telephone company cuts the service if you are not paid. Would the advisor then have to go to the bank and arrange a credit line for the funds until he was paid and how would they charge the client for the arrears in the payment. I believe the scandal that is causing this, is the result of failure of oversight of his firm in a normal way. More regulation is not the answer. We have good rules on the books, let's use what we have and make the regulators more accountable for their actions, after all where were the auditors on the broker dealer side and not catching the trades. Just one mans thoughts.