Subject: File No. S7-25-10
From: Scott McCormack
Affiliation: Granite Capital Management

October 29, 2010

Re: "Spousal Equivalents" in the Family Office

I am writing in strong support of including "spousal equivalents" to be a family office client as defined by the auditor independence rules. This is especially critical in the case of same-sex couples with no legal right to marry in this country beyond a few limited states.

I am a family member running a single family office and have two children with my partner. Our children are beneficiaries to certain family trusts and inextricably linked as clients to the family office. To exclude a same-sex "spouse equivalent" and co-legal parent of those children from being able to be a client of the family office would be exceedingly difficult. Certain trusts and accounts invariably include him as a co-beneficiary along with the children. Extricating those accounts from the family office would impose an undue and unjust burden given the lack of federal marriage rights. It would also go against the spirit of the very concept of "family office" in the 21st century.

Thank you for the consideration.