October 27, 2010
Subject: File Number S7-15-10
I am in favor of the 12b-2 however I do have strong concerns about allowing broker-dealers to establish their own fee structure. While the intent seems to be to protect middle America, in fact what this will do is make so advisors are no longer able to provide the personalized advice and service because the compensation to do so will be severely offset by the costs involved. In the end, those who have larger accounts and can afford to be in a fee in lieu account will still get the advice but those will smaller account (middle America) will be hurt. Please do not pass this portion of the rule.