Subject: File No. S7-15-10
From: Margaret Sheldon

August 23, 2010

In response to your concerns about 12b-1 fees I would like to offer these comments:

C shares allow me to offer clients greater diversification among fund families
C shares allow me to offer investments to small clients
C shares allow me to offer investment to clients with shorter term investment horizions

Some clients choose C shares because we share in the risk of my recommendations. If there investments go up, I make more money but so do they. Many of these clients do not have enough money to have investment advisory account.

Without 12b-1 fees some advisors would be more inclined to move clients more often - just the way that insurance agents do now. The fees also help us stay in business when times are tough and no new clients are coming in. I think lack of on-going fees would lead some advisors to become more transaction oriented -- like insurance agents. Also, not having on-going fees would make it very hard to help small investors.

Please remember that most advisors really care about their clients and want the best for them. The more difficult you make our business the less fun it is. You`ll chase us out and leave clients to the hard pushing want-to-be-rich guys or on their own -- both are scarey prospects.