Subject: File No. S7-15-10
From: Rodney Spradlin

September 15, 2010

12b-1`s are the sole source of income to our practice and servicing of our clients. it is an inexpensive way for clients to be serviced. all of our clients are main street clients. we would be forced to utilize a investment advisory program to service our clients, and that would double their fees. this does not benefit middle america. many of our clients are only paying an additional 35bps over the 25bps for a total of 60bps. no dialog was had over that and only the stock fund 12b-1 was referenced. Our BD and my practice would have to lay off employees as well. we urge you do not implement an unnecessary action that will displace workers and cost clients more in the end.

mr rodney spradlin
registered rep