Subject: File No.
From: Roger Clark
Affiliation: Registered Representative

November 3, 2010

I have been a registered rep for almost 40 years and File Number S7-15-10 is asking for trouble for many of those middle income or lower investors who rely on a Representative to guide them through the maze of "information" about a particular investment. Having the B/D's offer investments that provide little or no compensation to a representative, will drive the Registered Representative to those folks who can pay a fee, thus leaving those that need us most without any help self directing their plans. The "race to the bottom" this bill suggests will force me to not be there--I can't afford to work for free. The very people this type of legislative thinking wants to help will actually be causing them to be even more on their own.
I like the idea of changing the 12b-1 fees(name) to marketing and service fees or ongoing sales charges.