Subject: File No. S7-15-10
From: Michael J Schaffer
Affiliation: Owner

September 21, 2010

I hope in all the changes, you remember the client. The client will be the one who gets hurt when you take the very small fee away from the advisor who is being paid for service. Your already seeing changes from brokers switching clients money to other fund families hoping to continue the fee for a number of years.

As an advisor takes over business of retired or terminated employees, your asking for major trouble if they are not compensated. Wouldn't it make more sense to have the manager check with new client accounts and make sure they understand the fees?

The other problem is that major fund families have seen the excess fees as a 'gravy train'. The small fee paid to the advisor is not 'gravy'.

I hope these proposed positive changes, that will encourage "CHURNING" is some how going to be enforced for once. Moving from one family to the other so you can get paid is not in the clients best interest. Thanks