Subject: File No. S7-15-10
From: Doug Palfrey

August 9, 2010

As a professional financial advisor, I am against changes/eliminations of 12b-1 I must continuously advise and counsel (many times in the form of plain common sense to not buy high and sell low!) my clients, these fees are a fair way to help keep me in business...if you want to help out investors, I suggest the SEC look at these wrap accounts that use open ended funds...THEY are outrageous.