Subject: File No. S7-15-10
From: Steve Owings

November 5, 2010

I support the 12b-2 25 basis point rate for continued service to clients improved transparency. However I strongly oppose the idea of permitting mutual funds to create new classes of funds that allow broker dealers to set their own charges. This will lead to a "race to the bottom" in which service will get worse middle market investors won't get the quality of advice service they need. Thus, the people the SEC is trying to help the most will actually get hurt the most.