Subject: File Number S7-15-10

October 22, 2010

The ongoing service and contact of clients is a time consuming, expensive and detailed process. I still service clients who purchased funds some 20 years ago because they need this service and the work that is provided. One client was in my home today having tea and we reviewed her Franklin Utilities funds and at 80 she even has some emerging markets now, some years ago it was a free transfer.

Making sure a client continues to have an asset allocation that reflects their goals and objectives is important, especially during times of market stress. Rebalancing and fund evaluation to provide this within fund families is dear in database costs and other technology. It pays substantial benefits.

The fees that are earned to service clients ongoing ensures that I can pay a qualified licensed staff to service my clients as well as be available myself to service clients. These funds pay for 20% of my practice expense and service takes 80% of my time. Removing this small amount of ongoing compensation will quite simply cost clients incredible value. What should I say? The SEC doesn`t believe I should be paid for my work and I have no further value to you as your service contract expired after 5 years. How can this help a client?

Vanguard now blatantly discloses the value of an advisor in their marketing materials. It is ironic the largest fund company dedicated to low fees is a proponent of a professional advisor. Vanguard is not the right choice for everyone. As a CFA, Bachelors of Science from Cornell University, small business owner with 11 branch offices and staff, I urge you to sincerely evaluate the value that 12-b-1 compensation provides to clients.

We recently had great market stress. This was not caused by a 12-b-1`s. In fact, having advisors intimately familiar to their clients needs and available to answer the calls of millions of concerned clients helped our country and our clients. The bubble in bonds is going to place investors in yet another uncomfortable environment. Our clients are not being hurt by 12-b-1 fees. Our clients are being hurt by firms and individuals whose interest are in direct conflict with our clients.

Our objectives as professionals should evaluate the cost to the client to service their needs and the cost of the client to have no service. No advisor and no service are ultimately much more expensive to clients.

Mr. Keith Condemi, CFA
Registered Representative
MULTIfinancial Securities Corp.