November 2, 2010
Subject: File Number S7-15-10
I have been a licensed insurance professional and registered representative for over 13 years.
The proposed new terms "marketing and service fees" and "ongoing sales charge" in place of "12b-1 fees" are improvements.
I do not agree with permitting a mutual fund company to issue a new class of shares in order to be more competitive, especially in the market that I deal with - the middle and lower market investors.
Servicing my clients is crucial. In order for me to take the time to do what is ethical, as a self employed person, I need to be compensated. I am not licensed to charge my own fees for service. I don't wish to be because the overwhelming majority of my clients would not be able to do business with me if I did. These relationships are valuable because I do not charge a fee.
I understand you are trying to protect the lower and middle market investors, but in the long run they will actually be harmed without guidance and service if 12b-2 fees are drasticly lowered or abolished as proposed in File Number S7-15-10.