Subject: File No. 4-606
From: John C Forney, CLU ChFC AIF

August 16, 2010

As a career professional in the financial services business for over 40 years I am deeply concerned about the current consideration to change the policy on 12b-1 fees. One of the most difficult parts of my job is to maintain contact with my clients over a long number of years. Mutual fund compensation has been going down over the years yet my expenses as an independent businessman have been going up considerably. With 10 staff people to service approximately 1600 investment accounts we are stretched to maintain contact for changes with our clients. Families situations change over time and their investment needs change with them. Without the ability to stay in touch our clients will suffer. Most of our mutual fund accounts will provide ongoing compensation from 12b-1 fees of less than $100 a year. Should 12b-1 fees be reduced or eliminated our smaller client accounts will be affected the most with our inability to afford to maintain contact on an ongoing basis. Please consider carefully the elimination of 12-b-1 fees and the cost of doing business in the independent channel.