Subject: File No. S7-15-10
From: Candy J Lee
Affiliation: President and CEO, Financial Services International Corp.

September 2, 2010

Advisors benefit clients beyond simply making an initial investment selection and should have the ability to be compensated for their continuing service of the account. Behavioral economics studies illustrate that clients often make decisions that are harmful to their long-term fiscal health in times of boom and bust and an advisors guidance can be instrumental in keeping the client on track.

Clients already have the option of going the low cost route of purchasing a no-load fund or ETF in a self directed brokerage account and bypassing advisors altogether. The clients that choose to work with advisors value our investment advice, our guidance and reassurance through turbulent markets. When the advisors at our firm explain the multiple share classes of mutual funds to clients we find that they often select C shares due to the advisors compensation being linked to their investment performance and the freedom to switch or liquidate investments without having to consider the large upfront commission they just paid.

We strongly believe our clients need to know what they are being charged and how the advisor is paid. We see no reason why it should be hidden in the middle of a fine print prospectus. If you are concerned that the client does not understand how the advisor is compensated then please make the fund companies put it in big bold print on the front page of the prospectus and summary sheet versus taking options away from clients that want them.

The following are questions we believe are worth exploring with clients currently invested in C shares before the option is stripped away from them:

1. Do you prefer to pay your advisor upfront for selecting an investment even knowing they will get minimal income to service your accounts after they select the investment?

2. Do you feel you will get the proper attention and monitoring of your investments if your advisor is being paid more for finding new accounts than servicing the old accounts?

3. Are you comfortable that the funds you are buying will perform admirably for the long term and see no reason to change from the selected fund family?

4. Are you aware that if you choose an upfront A share option that only the non-commission portion is invested and that in a rising market environment it could take years before your return would equal that of a level load C share that invests 100% of your money?

5. Do you feel your advisor brings you value after the initial purchase other than just to provide distributions or administrative services to your account?

6. When the markets are crashing do you appreciate having an advisor to help you stay calm or to review your investments to see if they are still appropriate? When performing this review, do you prefer your advisor to have you incentive to switch you to a new product in order to generate a new commission?

7. Do you prefer to pre-pay for your advisors services or would you prefer to pay only for the time he is servicing your account?

8. If you dont like an investment you might not like the other investments that the fund family offers. Under these circumstances do you want the ability to change without penalty or loss of pre-paid commissions?

9. In order to pay for service on a level basis you may need to transition to a fee-based account that will likely cost more than 1% a year on your entire account value, not just on the amount invested. Are you willing to pay the additional cost to stay with your current advisor?

10. Do you like the fact that if your investments go down your advisors pay goes down, and as your investments go up your advisors pay goes up?

We use the fee-based model for our larger accounts as an alternative to C shares but it is too costly to small accounts. As an advisor you are forced to cover the additional administrative costs of billing the account and liquidating on a quarterly basis to cover fees. The C share option is the best full service client-focused advisor model available.