Subject: File No. S7-15-10
From: Bradley Brooks, CFA
Affiliation: CFA

September 12, 2010

Since the SEC is reviewing the 12b-1 fees, I am hoping the major mutual fund platforms such as Schwab and Fidelty will come under some scrutiny. The 40 basis points that they charge to be on their platforms is outrageous considering it perhaps costs them a couple of basis points to provide the service they do.

If the SEC is serious about lowering the cost to mutual fund holders this would be the best place to start. 25 basis point is the maximum these platforms should be able to charge, and personally I think it should be more like 10 to 15 basis points. If this was case it would allow mutual funds the flexibility to lower their own 12b - 1 fees since I know in the case of the firm I work at we actually run a deficit to pay for the right to be on the major platforms.

This issue would seem to be pretty straight forward, so I hope it doesn't take a couple years of analysis to start helping out the individual investor.

Brad Brooks CFA