Subject: File No. S7-15-10
From: Terry Fullmer CLU, ChFC

October 27, 2010

Dear Sirs or Madam

I have been working as a financial advisor for over 30 years. I support your efforts in establishing the new 12b-2 rules and also support the use of the terms "marketing and service fees" and ongoing sales charge" to improve transparency in disclosure documents. However, I strongly object to the SEC permitting mutual funds to issue a new class of shares at net asset value that would let the broker-dealers to set their own sales charge and commission amounts. I know that this sounds really good for the consumer but as in all thing there are two sides to it and I think it would eventually hurt the consumer. The reason being is that when a bidding war goes on the fees to the financial advisors will go down putting them out of business. The consumers would then have few options in getting advice.
Those that are wealthy could afford to hire advisors and money managers but those that need the advice the most will not have it.

I know that you are trying to protect the lower and most middle income investors but not having access to advisors will only hurt them. Thanks for listening.
Terry Fullmer CLU, ChFC