Subject: File No. S7-15-10
From: Adam Solano
Affiliation: Lakeside Financial Group

October 27, 2010

I have been a licensed registered representative for almost 18 years and I generally support rule 12b-2 improving transparency, etc. But I do not see the sense in further complicating our compensation by allowing mutual fund companies to establish a new share class so that B/D's can set their own pricing. The landscape of our industry has undergone so many changes that encumber the client-advisor relationship. However, at this moment in time, I believe there is a "Blue Ocean" opportunity for those of us who enjoy working the middle market; and I believe if this rule passes and changes the compensation within this industry, the "Blue Ocean" of the middle market will dissipate and the inclination which is already present within my industry to work with the upper market will be solidified. In other words, the upper market will be the only viable and profitable segment and the middle market will be grossly underserved by online and 1- 800#'s. People desire face to face interactions and want relationships built on trust when making financial decisions whether they belong to the upper, middle, or lower markets.


Adam Solano