Subject: File No. S7-15-10
From: Brad Windell

August 23, 2010

Clients normally save taxes and overall fees as compared to a fee based platform if they have less than $500,000 invested. C shares are frequently reallocated based on an increase or decrease in the various asset allocations. We use many different fund families saving the client front end loads. The ability to deducte expenses with out itemizing on the clients for 12-b 1 fees is advantageous to almost all clients. We feel we earn these fees by ongoing advice, which often entail liquidating positions for varios needs of the client. Usually within four of five years of an intial purchase. We have no objection to displaying fees paid to us as advisors.