Subject: File No. S7-15-10
From: Hunter W Bailey
Affiliation: Advisor

July 23, 2010

When fully disclosed and the advisor do thier job I feel the 12b1 is very helpful in assisting smaller clients. Alought I am converting my practice to fee based I find that I am able to provide lower fees to my C share clients with carefull fund selection. I notice it is only the fee for service people that are bashing 12b1 when the fee for service costs are actually higher

Well, I am switching rather than fight, but in the transition if my 12b1 fees are reduced 75% I will be forced to lay off two full time employees I will personally pay much less in income taxes and I will be forced to ignor my small clients or those who don't want to pay more for fee service.

I agree with the morality of removing the 75 bpts, but its easy to simply disclose them, give the client the option of converting to A share or stay as is.

Just make the fund companies send the client a letter after four years that disclosed the fees and give the client the offer to dump thier advisor.

If the C shares are reduced to A's the industry,employees,advisors and then the clients will be badly affected.

Some rep will even go so far as to churn accouts for commission, this is something that the C shares help eleminate. Service to the client was a very important benefit to all. Now will it come down to a point of sell and forget?