Subject: 'File Number S7-09-09'

July 1, 2009

Please reject this proposal deeming my firm to have custody of client funds since we are able to direct bill. The cost of a surprise audit required under this proposal will be unduly burdensome.

Thanks,

Justin B. Whelan III, CFP(R), CLU, ChFC

Biechele Royce Advisors, Inc.