Subject: File No. S7-15-10
From: mark a walter
Affiliation: Vice President Investments

July 26, 2010

Dear Sir/Madame,
It has come to my attention and those I work with that the SEC is considering some broad moves on 12b-1 fees for the first time in 3 decades. I would like for you to please consider that in servicing 'NON Managed" accounts we must be paid for all the work and research we do in order to keep accounts in good order and in line with the "know your client" rule. How can we possibly work for free or literally nothing if the fees are completely taken away or dropped to an abismal base? You must consider that the fees then hit all advisors grid and we are already getting only a minimal annual amount as it stands. This 'trail' is what pays our income and pays to keep us employed as we spend hours, days, weeks, months and years preparing new presentations for prospects and clients, updating and revising portfolios as peoples income needs change and as their age changes so do their investment needs and criteria. We must be the ones to work constantly for them as we do not earn salaries, this is what keeps us employed and what keeps us able to continually help the client to make sure the right portfolio is always maintained throught their life and our clients relationships with us.

I'm not here to beat a dead horse, but for those of you who are not full time advisors, you have to look at how we work for ourselves and the clients since we cannot pull annual salaries as you do and our time is our money as with an attorney or physician. We can only help them make money if we are making money. No one can work for free and continually monitor and advise and create without compenation. Please allow the C shares and or L shares to stay as they are and pay us as they do. This also is of benefit to the client as many clients cannot afford an A share load and we cannot due our job without proper compensation.

Thank you for your time and understanding of what we do and how we do it as an advisor.

Mark Walter