Subject: File No.
From: Troy D DeLair

October 27, 2010

To whom it may concern:

As a licensed financial advisor and registered representative for the last 19 years, I wanted to write in regards to file# S7-15-10.

Whereas I support the new 12b-2 rule, which would continue the 25 basis points fee used to ensure investors receive ongoing service and advice, I strongly object to the SEC permitting mutual funds to issue a new class of shares, at NAV, that would allow broker dealers to set their own sales charge and commission amounts.

I like the idea of competition based on price and cost, but I am afraid it will come at the expense of effectively removing the needed advice and service for middle market investors. A demographic, that arguably, needs it the most.

As broker dealers move to reduce their sales charges and fees, to gain market share, it may result in Registered Representatives no longer being able to financially justify the level of individualized advice and ongoing service we provide to our middle and lower demographic clients.

It would appear, that only the upper income investors, who can afford assets under management arrangements and higher cost and higher service classes of shares, will have access to personalized investment advice.

Investors with smaller account balances will be forced to self-direct their accounts, if they want to continue to own mutual funds, because their advisors will no longer be able to afford to spend the time needed to guide and advise them.

The people the SEC are trying to protect the most -(middle and lower market investors) will be hurt the most, since they will be deprived of the guidance and service they need and deserve.

It is my hope, as you move forward, that you will work to protect the needs of the middle and lower market clients, by providing a means by which they can continue to receive the advice and service they are in dire need of.

Thank you for your consideration and have a great day