Subject: File No.
From: James Mustard, ChFC

October 28, 2010

I have been a Registered Representative and licensed Life insurance agent for over 25 years. I think the new SEC rule 12b-2, which would continue the 25 basis points fee that is used to ensure investors receive ongoing service and advice is a good rule and makes it more transparent. However, I don't think letting broker-dealers set their own sales charge and commission amount would help anyone. In fact it would probably be detrimental to the smaller investor because the charges if they go to 0 then no one could provide the service and advice the client would need.

I would hope that the SEC would recognize the need for service does come at a cost.

Thank you,