Subject: File No.
From: David B Manuel

October 27, 2010

Reference: "File Number S7-15-10".

I have been a licensed insurance professional and registered representative for over 25 years. I support new SEC rule 12b-2, which would continue the 25 basis points fee that is used to ensure investors receive ongoing service and advise, and the SEC's proposed use of the terms"marketing and service fees" and "ongoing sales charge" in place of "12b-1" 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 allow broker-dealers to set their own sales charge and commission amount. Competition based on price and cost sounds good but will come at he expense of needed advise. As a result, only upper-income investors who can afford assets-under-management arrangements or higher cost/higher service classes of shares will continue to receive personalized investment advise. Thank you in advance for your hellp on this issue