Subject: File No. S7-15-10
From: Carl Camillo
Affiliation: NAIFA SFSP FPA

October 12, 2010

Placing a time limitation on C shares makes sense. The prospectus clearly indicates that C shares held for an extended period of time are much more expensive than A shares, especially if the client qualifies for a breakpoint. If B shares convert to A, then it is only fair to the clent that C shares should as well.

The account-level sales charges, however, is a horrific idea. While the SEC is hoping for increased competition/lower sales charges, the uninformed consumer would likely be exploited by a broker with questionable ethics. Furthermore, would a broker offer "breakpoints" similar to the ones that funds offer? The SEC polices breakpoint selling now, but such account level sales charges would allow a broker to skirt the issue completely. Let us not forget that, at heart, we are (or at least should be) a SERVICE business. Clients should not have to worry about haggling over sales charges. They should be involved in a trusting, long-term relationship with an advisor who is earning a fair commission to look out for their best interest. A client should evaluate advisors based on knowledge, experience, responsiveness and other factors....not because a competing firm is willing to undercut another then likely ignore the client afterwards because the transaction was just seen as a "sale" rather than the beginning of a relationship.