From: Scott E. Cooper
Sent: June 13, 2007
To: rule-comments@sec.gov
Subject: 12B-1 fees


The problem with 12b-1 fees isn't that they exist but rather how they are disclosed. I am a financial advisor who provides comprehensive financial planning services to clients. Over the years the purpose of these fees has changed , where today they primarily provide compensation to advisors for advisory services delivered. These fees allow for better service over time, which usually means better investing habits and behavior by the investor....i.e. sticking to the plan set up by the advisor they hopefully trust. Given the many alternative pricing options like wrap fees, 12b-1 fees are certainly less expensive, and for non qualified accounts, more tax efficient. Doing away with them would cause much bigger issues to the entire investor/advisor relationship, and in my opinion, be worse for investors in the long run. Preserve their integrity, but disclose them better.

Thank you.

Scott E. Cooper, CFP, CFS
Vice President
Economic Concepts, Inc. - Securities America, Inc.