Subject: File No.
From: Stephen G. Summerlin, CFP
Affiliation: Past President Florida Association of Life Underwriters

November 5, 2010

Thank you...I have 39 years in the financial services industry, most of them heavily involved with indusry legislation for the benefit of my clients first, then advisors and companies/providers. If my financial products are not good for my client first and foremost, I'm wasting my time trying to make the industry better for advisors and doesn't work that way. As you contemplate my remarks, know that I also speak for my 350 investment clients who are very satisfied with my sales charges,fees and most of all, service long after the "sale"

Yes to 12b-2 at 25 basis points disclosed to investors for servicing my clints years after the sale, often 10-20 years later. I cannot meet my serving promises to clients without this 25 basis point fee. Servicing (and often holding my clients hand during turbulant markets) consumes a huge part of each day in my investment practice. No 25 basis point servicing fee?...little to no service can be provivded, hence lost clients, many of them low to moderate income. Yes to 12b-2 fees

A resounding NO to giving broker dealers a share class for no fee mutual funds and allowing broker dealer's to set sales charges and advisor's compensation, especially since I am a full disclosure advisor (no complaints in 39 years)and the fees are easily justifiable when explained to the investor. Again, stop tampering with MY compenstaion which is now fair and equitable for the investor. Many of my client accounts are less than $50,000...I cannot afford to provide professional investment advice with "slased" sales charges for this lower class investor or, for that matter, my middle income investors requiring as much or more of my time to affect SUITABLE investments. Again, NO to a no fee mutual fund class and NO to giving any broker dealer authority to set sales charges which will truley result in discrimination to investors. To the regulators and legislators...this is a tough business to survive in under any circumstances, most especially in today's environment.. Don't screw it up even more