Subject: File No. S7-15-10
From: Michael David

July 24, 2010

The latest SEC proposal to limit 12(b)-1 fees is simply insufficient. Such fees should not be allowed under any circumstances (especially when a fund is closed to new investors). Currently many clients of mutual funds pay high fees which are entirely unwarranted and not adequately disclosed. With limited exceptions, total fees collected by operators of mutual funds continue to be excessive and cannot be reasonably justified. In summary, SEC regulators should do a better job of protecting the small investor.