Subject: File No. S7-15-10
From: Vladimir Rudy

October 19, 2010

12b-1 fees are supposedly to be used by fund companies to market the shares in the fund. There should be NO 12b-1 fees levied at all if: (1) The fund is closed to new investors (since there is essentially no more "marketing"). (2) The fund's assets have grown to a large enough size (say several billion dollars) so that the amount of regular management fees collected can support these efforts. Also, if fund assets grow to very large sizes, investor returns often deteriorate, so investors should not be forced to subsidize such excessive marketing.

Sales charges (loads) are supposedly to compensate outside brokers for selling fund shares. So these loads should NOT be charged if an investor is buying the fund shares directly from the fund (there is NO broker involved).

I am quite aware of these fees and try to avoid funds that levy them. I believe they are just an additional enrichment for fund management and do not help the investor at all.