Subject: File No. S7-15-10
From: Robert Keenan
Affiliation: CEO, St Bernard Financial Services, Inc.

July 26, 2010

While we are in full agreement that 12b-1 fees should be fully disclosed, the proposal to do away with "C" share fund classes places a burden on a financial advisor that wishes to add flexibility and liquidity to a client's portfolio.

If we wish to spread a client's assets among several fund families and re-balance on a regular annual or quarterly basis, not having "C" shares available would be very costly to the client in the form of increased fees. Re-balancing with either "A" shares or "B" shares is very expensive.

Also, for a client that has a five year or less time horizon for their investment, "C" shares are cheaper than either "A" shares or "B" shares when all costs are factored in.

Eliminating "C" shares is a bad idea.