Subject: File No. S7-15-10
From: David Darner
Affiliation: Cambridge Investment Research

August 19, 2010

BE CAREFUL. If you eliminate or curtail the 12b-1 fees, advisors will start "moving" money around so as to get paid again. Some reps. unfortunately already do this with "A" shares. Many "seasoned" representatives use "C" shares. they are more interested in a long term relationship with the client. Rather than "sell" them today ("A" or "B" shares) to get paid more and forget the client tomorrow, they go with a "C" share. If you cut off "C" share trails or reduce them, you will cause advisors to move the client around to start the process all over again in order to get paid. This would be detrimental to the clients and cause a whole new regulatory problem that would be hard to monitor. More regulation is the last thing we need.

David Darner
Cambridge Investment Research
Iowa City IA