Subject: File No. S7-15-10
From: Troy Zeller

August 11, 2010


Please consider that the average investor has had a return of 2.3% from 1990 to 2009, while the SP500 average has been 8.2%. Why the difference?

These are my personal opinions only.

While you can limit expenses, you can't regulate the behavior of investors. If a client wants to pay an advisor so they can assist them in finding the best investment for their needs and help them through any tough times in the market/investment, so they don't sell at the worst time, then clients should be able to pay for this help as long as they are making an informed decision.

They should be able to easily see all the costs of various share classes using something like FINRA's Fund analyzer, and even better like Morningstar illustrations that would generate the actual historical returns of an investment in all available share classes showing any upfront costs, breakpoints, ongoing costs etc. A higher cost may be worth it if the returns pay for it and that can be monitored as time goes on. Allow the client to decide for themselves showing not only the historical costs, but historical benefits/returns of the selections.

You need to be paid for your job and time, so do financial professionals. Let the clients see the various costs and allow them to make an informed decision and if they want to invest their funds.

Thank you,

Troy Zeller

(My personal opinion only.)