From: Richard P. Halverson []
Sent: Friday, September 06, 2002 1:01 PM

Subject: Comment: File No. S7-28-02

Re: Definition of Custody, Invoices for fees sent to an authorized Custodian.

The following should not fall under the definition of custody. In circumstances where a client has directed an advisor to send invoices for fees or other expenses to its custodian but where the advisor does not have power of attorney to sign checks on the client's behalf nor is authorized to deduct fees directly from the client's account. Under these circumstances the advisor has no independent access to clients funds. The custodian, acting as agent for the client, receives and approves the invoice and then authorizes payment.


Richard P. Halverson
Great Northern Capital