Subject: File No. S7-15-10
From: Z. Jane Riley

October 28, 2010

RE: Release No. 33-9128 File No. S7-15-10

To Whom It May Concern:

We feel the proposal to modify Mutual Fund Distribution Fees is not in the best interest of the investor. The distribution fees as currently set up give representatives an incentive to service the investor and strive toward growing the investors account in the long term. The proposal would discourage the use of C shares, which are appropriate for many investors that do not have a long term time horizon, but look at maintaining the account for 13 months to six years. Studies show the average mutual fund account is only held for 4-7 years. We feel the proposal would hurt the middle and low net worth investors considerably. The compensation changes would make these accounts undesirable and leave the investors to self direct their investments.

Thank you for considering our comments against the revision to Mutual Fund Distribution Fees.


Z. Jane Riley, CSCP®
Chief Compliance Officer
The Leaders Group, Inc.