Subject: File No.
From: Dennis T Higuchi, CLU, ChFC
Affiliation: Registered Principal of Transamerica Financial Advisors

October 27, 2010

Comments Attached

Re: File Number S7-15-10

I have been a licensed registered representative for over 19 years. I support the new SEC rule 12b-2 however I strongly object to permitting mutual funds to issue new class of shares at NAV that would allow B/D's to set their own sales charge and commissions.

My associate reps and myself serve many clients who are primarily small to middle market clients. If fees are controlled by the B/D's and competition drives those fees lower, many of us will not be able to advise and service these clients.

Please help us to continue to service our middle and lower market investors. Thank you for your consideration.

Dennis T. Higuchi