Subject: File No.
From: Michael Theis
Affiliation: CLU ChFC

November 5, 2010

Re: File #S7-15-10


I have been a licensed insurance professional representative for over thirty years. While I support the new SCC rule 12B-2, which would continue the 25 basis fee to insure that investors receive ongoing service and advice, however, I object to the SCC permitting mutual funds to issue a new class of share at net assest value which would allow broker/dealers to set their own sales charge and comission amount. I live in a rural area and have investors with accounts as small as $1,000. Their net worth is just as important as that client with $100,000. How can I afford to service them when the fees structure is so low to prohibit service. Just today, in competition I was explaining to an investor my fee as compared to a managed account fee that was twice as high. Will I be forced, also, to offer my cliental an advisor account which allows a higher fee? Taking this into consideration, please revisit the your current proposal allowing a new share class by mutual fund companies.