Subject: File Number S7-15-10

October 27, 2010

I have been a licensed insurance professional and registered representative for over 8 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 advice, and the SEC's proposed use of the terms "marketing and service fees" and "ongoing sales charge" in place of "12b-1 fees" 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 the expense of needed advice and service for middle market investors.

The latter turns the financial advisory profession into a commodity - where the only value is price

Thomas R Schaffer
Partner
Raleigh General Office