Subject: File No.
From: Roger L Owens

October 27, 2010

File Number S7-15-10

I am a small advisor in a small town in Elkton, Maryland. I have been in the financial services business for over 25 years and have about 1000 clients.

I agree with the proposed changes with 12b-1 to affect and improve transparency. However, I believe the ability of Broker Dealers to set their own fee schedule with a new fund class is a tremendous mistake.

Most of my clients are inexperienced novice investors who rely on my advice, encouragement, handholding, and suggestions in order to invest and save for their goals. Changing the fee structure and fund class will only encourage Broker Dealers to provide LESS service to these investors who need help the most. High end investors will still have access to help and advice but where does that leave the millions of Average Investors?

Thanks for you consideration.

Please do not allow Broker Dealers to race to the bottom and leave average investors without the help they need.