Subject: File Number S7-15-10

October 21, 2010

Mr. Jeffrey Vogt

1) What ever happened to freedom of choice. Don`t assume that the client`s don`t watch their accounts and understand what they have. Should they be allowed to choose how they wish to compensate the advisers that advise them?

2) Our business very service oriented, we don`t sell a product so to speak. The assets that a "small" client has is as important or even more important to them than a "large" client. The 12b-1 or what I consider to be service fees allows us to take care all of our clients equally. Without it the "small" clients will become transaction based and either ignored, or worse have their accounts churned to generate the necessary revenue to service them.