Subject: File No.
From: steve asche
Affiliation: Member NAIFIA

November 2, 2010

Comments,

I am writing regarding the conversations regarding the possible removal of the 12B1 title and fee. This fee is a very important part of ongoing service level we are involved with in servicing our clients on a regular basis. Being a licensed agent for 19 years I regularly visit with people on a daily basis that have questions about their accounts. The middle class will not get the service the need if this fee is eliminated rather the name under 12B2 is fine with a new name calling the fee.

I would ask you what the savings rate has been for individuals? We all know it is not as high as it should be and removal of this service fee would have a negative impact on the savings rate also. I have clients that have not added to their investments and have been retired for over 20 years and they need the personal touch on a regular basis and this measure would hurt them.