Subject: File No. S7-15-10
From: Dwight A. Herrington

October 18, 2010

1) Fees structure should be clearly stated at time of sale. Not lost in foot notes, not referred to by jargon or SEC code but clearly described as fees paid to the fund sponser.

2) The impact of fees should be clearly shown on fund statements. For example value at beginning of statement period, market gain/(loss), fees to sponser, value at end of statement period.

3) An annual statement showing fees paid since purchase of the fund should also be required. The long term cost of making long term investments should be known and made available for individual investors.