Subject: File No.
From: Stephen J Robey
Affiliation: CLU, ChFC, MSFS

November 2, 2010

-I've been in practice a number of years and have come to depend on the 12b-1 fees as an ongoing incentive to continue to serve mutual fund investors. Changing that environment would not be of help to the client or to people like me who continue to service them. I do not think a negotiated fee schedule would be of benefit for this level of customer. As it is, it provides a level playing field. These fees are fully disclosed through the perspectus from the various companies we work with. It is not buried.