Subject: S7-15-10

October 27, 2010

To Whom It May Concern:

As a registered representative, I understand that increased disclosure is an ongoing concern in the business. I am not opposed to disclosure to clients, that is how people are made to feel comfortable with their decision to purchase any of our various products.

The problem that I have is with the thought of offering mutual funds at NAV and allowing broker dealers to decide what sales charges to assess on each fund. This creates a problem due to the fact that each broker dealer is going to see how cheap they can be in a race to the bottom for market share. This ultimately will deprive middle class investors of the ongoing advice that they need regarding their investments. It will create a situation where assets under management clients will be the only ones receiving ongoing advise due to the fee that their assets generate.

Please listen to my concerns as well as my colleagues. This is not a good way for this industry to move. It is just a way to guarantee that people won't receive the services that they need.

Dan Kalina
Financial Services Professional*
New York Life Insurance Company