From: David M. Crooks
Sent: June 13, 2007
To: rule-comments@sec.gov
Subject: 12b-1 Review


To whom it may concern,

I am a 23 year veteran of the investment business, and approximately 60% of my client's assets are in non-fee based A share mutual funds, in some cases purchased 15-20 years ago. We employ a buy-hold strategy. If 12b-1's were to disappear, I would have no choice but to either resign as the broker on those accounts, move them to our fee based platform with a minimum fee of 1%, or start moving assets in order to generate commissions. I fail to see how any of these approaches benefit the client.

Sincerely, Dave

David M. Crooks, CFP®, CLU, ChFC, RHU
Wealth Management Advisor
Bleakley, Dwyer, Schwartz, Cooney & Finney LLC