Subject: File No. S7-15-10
From: Michele Perrault

August 20, 2010

I believe that the proposal to essentially do away with "C-Shares" is a mistake that will harm investors.

Yes, the total cost of holding A-shares vs. C-Shares, has a point at about 8 years where the investor would be better off from a cost standpoint. That calculation assumes that the Investor is totally certain that they will stay in that fund family for that very long timeframe. It also assumes that the Mutual Fund family delivers superior performance in all asset classes and strategies and will continue to do so for that whole time frame.

But----
1. Most investors cannot make that assumption-- personal circumstances can and do change. And we certainly know that the markets do change quite actively.
2. If the Investor pays the A-share charge up front then makes a move out of the fund family, he/she will have paid in advance for services they would not in fact receive.
3. In a perfect world, every fund family would have 1st Quartile managers in every asset class strategy, but that is just not reality. Different fund families execute certain strategies better than others. So the investor will not have the best performance if they are forced to stay in the same family because they have already paid an upfront sales charge.
4. The sales charge an Investor pays up front reduces the net dollars invested which creates a drag on performance.

In summary, C-Shares allow the Advisor to bring best of breed strategies to clients, allows the client to "pay as you go" for performance and the freedom to hire or fire managers as warranted by performance or service.

Thank you for considering my comments.