July 19, 2007

I am a licensed registered representative as well as an Investment Adviser Representative (IAR). As such I can charge fees for investment advise as well as earn commissons on the sale of investment products.

In return for providing ongoing service and continuing advice to my clients regarding their investments, I receive trailing compensation much in the same way that insurance agents receive renewal commissions on the life insurance policies they sell. This trailing compensation is typically paid under a written plan adopted pursuant to SEC Rule 12b-1.

My clients receive substantial value for these fees--I meet with them on a regular basis and provide on going investment advise. I count on the 12b-1 fee to provide me ongoing compenstioan for the many hours I spend with my clients and for the countless hours of research and dur dilligance I perform on their behalf.

As an IAR, I also have clients who pay an investment advisory fee to me for my services. I don't view my clients differently whether they pay a 12b-1 fee or a wrap fee. I would very definitely view them differently if my on going compensation was eliminated on the the clients paying 12b-1!

I believe the elimination of 12b-1 fees would do considerable harm to those investors who need and want ongoing investment planning advice and counsel. If 12b-1's were eliminated, I would have no choice but to transition my clients to a wrap based platform. The burden on myself and my client's would be significant. In addition, they would loose the tax advantages of paying there fee by virtue of 12b-1 fees vs. an advisory fee.

My clients expect our office to be available and to respond quickly to a variety of questions regarding their investments. I have never received complaints from my clients about the amounts they are charged for the services I provide to them. My clients expect me to be compensated for helping them achieve their long-term financial goals. If 12b-1 fees were eliminated, while the client might save the amount in 12b-1 fees he or she would end up paying as much or more in hourly or asset-based fees to receive the same service.

While I support complete and clear disclosure, for these reasons, I urge the SEC to reject any proposal to eliminate or restrict the payment of 12b-1 fees to registered representatives for providing continued service to their clients.

While it is possible that the 12b-1 fee has moved beyond it's original purpose, it serves perhaps and even more critical purpose than ever - the ability for the client to receive on going counseling by someone who has a vested interest in their welfare

Thank you for your consideration of my views on this subject.