Subject: File Number S7-09-09

August 12, 2009

Good Morning

I wish to be on record regarding the proposed custody rule (1A-2876).

I have a small firm and primarily use Charles Schwab as custodian. If I had to pay for a surprise audit by an independent certified public accountant, it would be a financial hardship.

Charles Schwab’s compliance department, along with their procedures and processes are very sound and redundant. I regard the proposed rule as very unreasonable.

Another concern I have is having non regulatory personal obtaining client information.

Thank you

William McElroy
Guardian Plus