Subject: File No. S7-15-10
From: Robert Norton
Affiliation: Registered Securities Principal

July 30, 2010

Mutual fund wrap programs can charge 2% or more and seperate accounts as high as three. They are not as tax efficient as mutual funds either. My practice is made up of small to mid sized investors (families), and outside of a more straight forward disclosure of the existing fees, they will not benefit from these changes. Every industry has their bad apples and they need to be rooted out with all haste and vigor. But, mass changes for the sake of change is wrong. Page one of every prospectus and or purchase agreement could have bold disclosure of applicable fees. Make it so you don't have to be a lawyer to read them. I would appreciate that, it would save time in explaining the differences. You are contemplating changing this industry in a way that will not get the desired result. It will assuredly drive many of us who run small ethical practices out of the business and in turn leave our clients without the trusted advise they need and have come to rely on.