Subject: File No. S7-15-10
From: Ron Zeitz

September 12, 2010

For many advisors such as myself the fee paid from a mutual fund is how we're paid to provide the continuing service clients so desperately need. Our group's average fee to a client is .5% per year, certainly not exorbitant. If the fee paid from a fund is reduced, or eliminated we essentially would be giving ongoing advice for no fee. If we moved these same clients to a fee based model, the bottom line to them would be that they're paying more rather than less. An example: a C share bond fund has a total expense ratio of 1.2%, that same fund in the A share format has an expense of .6%, if that fund then is wrapped at 1%, the client's total fee is now 1.6%. The fee to the advisor is the same, but the client's total fee has increased by .4%. If the ultimate goal is to reduce fees to clients, eliminating the C share format will end up doing just the opposite.