Subject: File No.
From: Adam Kilbourn, CFP, CLU
Affiliation: President, NAIFA of Southern Nevada

November 1, 2010

Dear SEC,

I am a CFP here in Las Vegas and have sold investments and advice for the past 10 years. I am also the president of the local professional association, NAIFA of Southern Nevada, with over 250 members who service 10's of thousands of clients here in Nevada.

If you change the 12b-1 rules, there will be a reshuffling of the deck. Changing the rules is not always a bad thing, but this will change the business model. Our clients rely upon the advisor for their advice. As broker-dealers lower their sales charges and fees in an effort to gain market share, it will no longer be financially feasible for registered representatives to continue to provide the level of individualized advice and ongoing service that we currently provide to our middle and lower market clients.

In order to provide their service, advisors will be forced to charge a seperate fee for their advice. I believe in the end this will result in a similar situation that currently exists. Bottom line is that advice is an expense and needs to paid by the client. There's no magic third person that pays these expenses, all bills are ultimately born by the client. If you pull the 12b-1 fee, will the advice still be there? You require us as advisors to know our client and to document all the advice and investing we do, we must be compensated somehow for this work. If not, you will see an exodus of talented advisors from the business. If you make it too expensive to operate and don't provide a source of income for that expense, the advisor will cease to exist. Will all clients be regulated to the 800 number of some massive corporation?


Adam Kilbourn, CFP, CLU