Subject: File No. S7-09-09
From: Steven D Podnos, MD, CFP

May 22, 2009

Fee only planners who use approved custodians and have custodian monitored limits on fee withdrawals (Schwab, Fidelity, TD Ameritrade and others) are not an issue. To ask these advisors (usually solo practitioners) to submit to annual exams at great cost and time does no service to their clients.

I'd recommend excluding this highly ethical group from any changes in the rules