Subject: File Number S7-09-09

July 1, 2009

I have great concerns about this rule. In a time when small independent advisors are struggling to stay profitable, it is not fair nor wise to force them to incur added costs. Compliance is already a huge cost and time commitment. I strongly urge that you do not adopt this rule.

James P. Dew
CFP(r), MBA, ChFC
Dew Wealth Management