Subject: File No. S7-15-10
From: Jim McPartland, CLU, ChFC
Affiliation: TrueNorth®

October 27, 2010

Dear Sirs:
I would like to thank you for your work on the file referenced above. Certainly plain English about the 12b-1 costs is needed and your file sounds like a good way to handle that.
However, I would suggest that the idea of letting B/d's set their own rates for these costs is a flawed piece in this file. I believe with all my heart that folks who are my clients need ongoing service and guidance. It is why we meet regularly to review what they have and what their investment plans are doing. However, allowing b/d's to set rates will result in another round of lowering these costs and making it unfeasible for me to afford this level of service to the smaller accounts that need it most.

Please do not set off this price war where the ultimate result will be people investing without help that is critically needed beyond the initial purchase!

Jim McPartland, CLU, ChFC