Subject: File No.
From: David A Sewell

November 1, 2010

While I support the new 12b-2 rule, I have some concerns regarding the plan to allow a new class of mutual fund shares at net asset value. While competition is a good thing, I feel that smaller investors will be deprived of good investment advise because lower sales charges and fees will make helping small investors a losing proposition for the broker dealer. We are already seeing some of this happen with higher minimum initial deposits. Investors with larger portfolios will continue to receive advise as they always have, but the middle and lower market investors will be left on their own. I don't think that is what the SEC is trying to accomplish.

Dave Sewell