Subject: File No.
From: Bruce E Siennick, CFS, CLTC
Affiliation: NAIFA

November 5, 2010

RE: File # S7-15-10

I have been a licensed insurance and registered rep for over 30 years. My clients look to me for help in not just how or where to invest, but setting out a strategy to help reach their goals. I do not charge a fee, I am compensated by products that are purchased to meet these goals. My clients know that "service is my middle name", that's why they stay with me through all kinds of environments My second client is still with me, dating back to Dec 1972 People need help. I never wanted to be someone who was only looking for the transaction, I BUILD RELATIONSHIPS, and that takes time, being able to provide services that companies working just on price don't offer.

I strongly object to the SEC permitting mutual funds to offer a new class of shares at NAV that would allow B/Ds to set their own sales charges and commission amounts.

Competition based on price alone sounds good on paper, but it will come at the expense of needed advice and service. I work mainly with the middle market, they are underserved and relationship building is extremely important here.

I support new SEC rule 12b-2, and you should too.

Thank you,
Bruce E. Siennick, CFS, CLTC