Subject: File No. S7-15-10
From: Anthony Czarzasty

August 20, 2010

The proposal to change "C-Shares" is will put investors at a disadvantage.

If the total cost of holding A-shares is more effective than C-Shares at about 8 years, it assumes that the Investor actually stay with the fund family for that very long timeframe. And, it also assumes that the particular Fund family will deliver performance in all asset classes and will to do so for the whole time shares are held.

However, most investors cannot make that assumption-- personal circumstances can and do change. And so does the market. If an investor pays an A-share charge and then has to move out of the fund family for whatever reason, they will have paid in advance for management they did not actually get.
It would be great if every fund family had 1st Quartile managers for every fund, but that is just not reality. Fund families are more expert on certain strategies than others. So an investor "forced" to stay in the same family because they have already paid a sales charge, will not have the best performance. And the charge paid up front reduces net dollars invested and reduces the amount of money at work.

Finally, C-Shares allow an Advisor to bring the best managers of a particular asset class or strategy to clients, lets the client to pay annually for performance and service hire or fire a manager if they dont live up to expectations. Thanks