Subject: File No. S7-15-10
From: Daniel R Purcell, Jr.

September 30, 2010

Better disclosure is welcomed. I have been in the finance industry for over 30 years and cant begin to count the number of individuals that I have met,counseled,spoken too that clearly do not have a basic understanding of the costs of investing.

Herein lies the problem there are many investment choices in many different industries. Only showing costs distorts the real return to customers. For example a bank will claim there is no cost or profit to a customer on a Certificate of Deposit. I was a Bank CFO. One of my responsibilites was to manage interest rate spread. The profit before expenses as measured by the difference between interest paid on liabilites (CD's, Money Market accounts, Savings accounts and other interest bearing deposits) and the interest recieved on assets (Primarily Loans and Investments). That number was never disclosed to the depositors. It was often upward of 3% far higher than any 12b-1 fee.

Often people get confused on fees as to whether they are annual or one time. Additionally they often subtract the fee percentage from past performance whether or not it has been included in the past performance.

I am extremly opposed to letting firms charge their own rates as my experience has show many individuals don't disclose well enough that the consumer understands what it means in totality. Now you will have added another layer of confusion to the consumer. Additionally you may be giving an unfair advantage to larger firms that have the ability to negoiate revenue sharing which few if any customers understand.

I regulary deal with individuals who have accounts with firms that have revenue sharing and they have no concept of what that means.


PS Get spell check on here so you can better read my thoughts and not focus on my limited keyboard skills.