Subject: File No.
From: Kenneth Grace

October 27, 2010

With over 35 years of experience as a licensed insurance agent and Registered Representative, I want you to know that I support the new SEC rule 12b-2. People today need advice more than they ever have and the 25 basis point fee assures that they have me on their team. This 25 basis point fee is really a marketing and service fee and as such should be disclosed properly.

I oppose the SEC allowing broker dealers to have a new share class group of mutual funds available to them to be able to set their (the BD) own sales charge and commission schedule. IF the BDs lower sales charges, the registered rep will continue to move to the upper income and net worth markets and leave millions of middle and lower income people un-served. The best protection for the middle and lower middle markets is a registered representative that can maintain profitability while serving that market segment.