Subject: File No. S7-09-09
From: Rick A Johnson, CASL, CFP, RFC
Affiliation: Marian Financial Services, Inc.

August 18, 2009

Ms. Murphy,

Please do not put the onerous requirement of surprise audits on small registered investment adviser firms, just because we debit fees from client accounts.

When we debit fees, the client receives an invoice showing how the fee was calculated. They receive a statement from us showing their account value on the date of the fee calculation. In addition, the custodian, Schwab Institutional sends an account statement showing the deduction of the same management fee.

We feel this is a more than adequate sytem of checks and balances.

The protection of client's funds is of utmost importance and I feel that your focus needs to be with firms who have custody at other than qualified custodians.

Very truly yours,

Rick Johnson, CASL, CFP, RFC
Chief Compliance Officer
Marian Financial Services, Inc.