Subject: File No. S7-15-10
From: John M Walborn, CFP
Affiliation: President, Walborn Associates Inc.

September 16, 2010

I demand that the SEC permanently grandfather existing share classes of mutual funds into it's current plan for reform. Permanently grandfathering is needed to preserve business models and client relationships that have been legally established when the accounts were sold by prospectus. If this is not done, clients will be left with fewer servicing options as well as increased costs. There is plenty of competition from no-load fund companies to give investors an option if they do not wish to pay a commission and/or 12(b)-1 fees. The C share which typically pays a 1% trailer on the account value allows the same opportunity for profit that is available in an asset-based managed account without a middleman or third party to ann expenses. Given the volatility of financial markets for the last decade policies of the SEC should be to give investors more access to advise, not less.