Subject: File No. S7-15-10
From: Doug Lusk
Affiliation: Financial Advisor, Royal Alliance Associates

October 13, 2010

You must know that 12b-1 fees allow me to provide ongoing services to very unsophisticated investors. Eliminationor modification of the fee would necessitat me to cease serviceing these small accounts.

I encourage you to leave 12b-1 fees as they are