Subject: File No.
From: Jennifer Shepley
Affiliation: NAIFA

November 9, 2010

This is regarding File Number S7-15-10. I am a licensed insurance professional and registered representative working in MA for over 13 years. I support SEC rule 12b-2, however I object to the SEC permitting mutual fund companies issue a new class of shares at NAV that would allow broker-dealers to set their own sales charge and commission amount.
As broker-dealers lower their sales charges and fees in an effort to gain market share, it will no longer be feasible financially for registered representatives to continue to provide the level of indiviualized advice and ongoing service that we currently provide to our middle and lower market clients. My fear is that only upper income investors who can afford assets-under-management arrangements will continue to receive personalized investment advice.
Over 95% of my clients are middle income investors and small business people I am concerned they will suffer. I understand this new ruling is only tring to protect them. Thank you for your consideration in this matter.