Subject: File No. S7-09-09
From: Eugene Hammons
Affiliation: Pres., Creekside Investment Mgmt., Inc.

August 10, 2009

We have been made aware of proposed rule changes that would mandate an annual audit for RIA's that have a limited power of attorney for the purposes of dispensing client funds to pay investment management fees, and although not mentioned to dispense funds for trade settlement.

Creekside Investment Management, Inc (CIMI) is a registered investment advisory firm under the auspices of the 1940 act. We have been in business for over 19 years. Since day one we, like other RIA's, have offered the option to the client of payment of management fees from the account, or by direct billing to the client. Many choose the former for the sake of convenience.. If they do elect to pay fees from the account, CIMI adheres to the practice of sending the client a copy of the invoice so they know what they are paying and on the agreed upon basis.

Our fees schedules are a manner of public record, and, unlike Bernie Madoof, are our only source of revenues and income. All client money and securities are held in safekeeping by a third party registered firm subject to oversight by the SEC, NASD and others. Clients of CIMI receive copies of trade confirms as they occur and monthly statements from the third party firm. In addition CIMI reports to clients quarterly appraising them of all of the activities of their investment portfolios. Therefore everything we do is totally transparent and is driven only by a strong passion to succeed on our part. This is a conventional business model that is time tested and successful. There is little reason to subject it to useless and burdensome regulations promulgated by a single but high profile aberrational experience that should never had been permitted to operate in an otherwise pristine service to the public..

CIMI is a small firm, serving a select group of clients in long standing. To subject it, and many others of similar ilk, to the added expense of an annual audit will serve no useful purpose.

Eugene C. Hammons

Phone: 800.830.7085
Fax: 979.830.0657