Subject: File number S7-15-10

October 27, 2010

I have been a licensed life insurance professional for over 30 years, and a registered rep for over 20 years. While I support SEC rule 12b-2, I strongly object to the SEC permitting mutual funds to issue a new class of shares at NAV allowing broker dealers to set their own sales charge and commission amounts. Certainly as the BD's would gain market share, the registered rep would not be able to continue in the service on most middle and lower income investors. Please stand opposed to this element.


Barry A. McBride, CLU, AEP
President, Sun Cornerstone Group, Inc.