Subject: File No. S7-15-10
From: Lisa Mullins

August 20, 2010

Dear Ms. Murphy,

I'm writing this letter to address my concerns over the proposed reform to 12b-1 fees currently being paid to advisors like myself.

The existence of 12b-1 fees allow me to provide service and ongoing support of individuals and retirement plan participants. Without this payment; I would be forced to only work with clients who have greater than $250,000 to invest. In my practice, those clients go into a managed account program and are charged a fee based on their account value. That fee is billed quarterly and disclosed to clients in a separately billed invoice.

Individuals with less than $200,000 would not be a candidate for managed accounts and therefore a placed into mutual funds or investments on a transactional basis.

The average investor needs advice on how much to save and how to appropriately allocate investments among the vast number of choices available. In the absence of 12b-1 fees, I don`t have any incentive to seek out those individuals as clients. Don`t you think these individuals deserve service and and advice, perhaps even more than those who have greater resources and assets?

I'd be happy to discuss this further or serve in some capacity to the process of finalizing these amendments.


Lisa Mullins