Subject: File No.
From: Juli McNeely
Affiliation: NAIFA

November 1, 2010

My name is Juli McNeely. I have been a licensed insurance professional and registered representative for over 15 years. I hold the CFP, CLU and LUTCF designations. I am taking over my fathers agency - he has been in this business for 45 years. Our agency is located in a small rural community in Central Wisconsin.

Many of my clients invest smaller amounts of money on a regular basis. I continue to provide ongoing service on these accounts. Because of this, I support the new SEC rule 12b-2, which would continue the 25 basis points fee that is used to ensure investors receive ongoing service and advice, and the SECs proposed use of the terms marketing and service fees and ongoing sales charge in place of 12b-1 fees to improve transparency in disclosure documents.

I do take issue though with the SEC allowing a new class of shares at NAV that would allow the Broker Dealers to name their own sales charge and commissions.

One the things I believe my clients appreciate most is the ongoing service we provide in our firm. Where price competion may sound good, it truly could cost consumers a vital piece that may be taken for granted....SERVICE. People's lives change all the time. Their needs and objectives change. They need a financial advisor for ongoing advice as these changes occur.

Once again, this type of change will make it difficult to provide valuable service to the smaller accounts. Those at a higher account value can afford to pay an ongoing fee but those with smaller accounts will be left to fend for themselves. And finally, those that the SEC is trying to protect will be hurt more in the end.

Thank you for considering my point of view in this important matter.

Juli McNeely
McNeely Financial Services, Inc.
Spencer, WI