Subject: File No.
From: William T. Beemer, CLU, ChFC
Affiliation: NAIFA

November 2, 2010

Dear Elizabeth M. Murphy,

I have been an agent for just over 22 years and am nearer the end of my career, then the beginning. The proposed change to mutual fund shares at net asset value I fear will cause much more harm to the investing public then the current 12b-1 fee currently in place. The change will do two things for sure, cause more churning which is seldom really necessary, and leave the vast majority of investors without counsel from a professional. Although agents don't make a lot from 12b-1 fees, it is some compensation for the time we take to work with clients. Most of those that invest with me have less then $100,000.00 of assets that I manage and if there was to be a negeotiated charge for those fees, the cost to the investor would be much more then the 12b-1 fees, or we would just not work together.

The majority of the investing public will not make good decisions as to what to buy, when to buy, or when to sell. If left on their own you have done them much more harm then you realize.