From: Dean Koci
Sent: July 15, 2007
To: rule-comments@sec.gov
Subject: File No. 4-538

Dear Ms. Morris:
I am a licensed insurance professional and mutual funds salesperson at Northwestern Mutual.
I recently became aware that there is the discussion of the possible elimination of 12b-1 fees. These small residuals on investments I believe to be crucial to service oriented investors. I am a relatively new advisor in the industry; however, my clients appreciate having me manage there investments in relation to the rest of their financial plan. I am very familiar with the "no-load" solutions offered by various online companies and have found that the ~90% majority of clients I meet are happy to utilize the funds associated with 12b-1. Not only do they have access to more than a 1-800 number, they also receive improved performance- even after the sales charge. Without this fee it would be nearly impossible to adequately service clients.

I believe the elimination of 12b-1 fees would do considerable harm to those investors who need and want ongoing investment planning advice and counsel. A significant majority of my clients expect our office to be available and to respond quickly to a variety of questions regarding their investments. I have never received complaints from my clients about the small amounts they are charged for the services I provide to them. My clients expect me to be compensated for helping them achieve their long-term financial goals. If 12b-1 fees were eliminated, while the client might save a small amount in 12b-1 fees he or she would end up paying a much larger amount in hourly or asset-based fees to receive the same service.

For these reasons, I urge the SEC to reject any proposal to eliminate or restrict the payment of 12b-1 fees to registered representatives for providing continued service to their clients. Thank you for your consideration of my views on this subject.

Cheers,

DEAN KOCI
The Northwestern Mutual Financial Network
600 W. Broadway Suite 600
San Diego, Ca 92101