Subject: File No. S7-15-10
From: Joel Adams

September 20, 2010

As an independent advisor affiliated with Raymond James Financial Services I recommend mutual funds to my clients. My fees are based on assets under management. For larger clients, I handle their accounts under an advisory fee and we buy the funds and other securities without a sales charge.

My challenge is smaller clients (those with less than $100,000) for whom the advisory fee is not appropriate or cost effective. Our practice has served small clients, not because they are profitable, but because we feel they deserve good advice. I have used "C" shares for these clients because I actively service and monitor these accounts for as long as need be. I like to be able to explain that my compensation will be the same no matter which funds we choose and that the compensation is linked to their owning the fund rather than the act of purchasing the funds. The "C" shares offer minimal or no exit fees which provide liquidity if goals change or the fund changes. Without the "C" share or something like it, we would probably cease serving small investors because the expense of bookkeeping small advisory accounts would move some of our smaller clients from marginal to unprofitable.

I have clients from the mid eighties who bought tradtional "A" shares and I still service and advise these clients even though the compensation structure was designed for a single transaction and not a long term relationship. When "C" shares came out, I saw the opportunity to maintain long term relationships that were benficial to both my client and to me.

I hope in your consideration of these proposal that you consider advisors who focus on the long term success of their clients and not on the advisors and firms who concentrate on trading profits.

Mr. Joel Adams
Financial Advisor