Subject: File No. S7-15-10

October 15, 2010

The 12b-1 fee serves a vital purpose in my ability to service my clients that have such investments. In the absence of the 12b-1, there will be far fewer Financial Advisors and to that end, client`s without the guidance and expertise to serve their needs. I have never, in my 18 years, had a single client complaint regarding a 12b-1 fee and all are fully aware of my compensation structure and are more than willing to pay for it.

Glen Viditz-Ward
Viditz-Ward Financial Services, Inc