Subject: File No.
From: John S McMahon, CLU, ChFC
Affiliation: Registered Representative

November 2, 2010

Re: S7-15-10, I support 12b-2 charges going forward, but strongly oppose a new NAV share class that would allow broker-dealers to set their own fees and charges. The effect will be to drive expenses so far down that experienced and weel-versed agents will get out of the business. The middle class will end up being underserved, poorly advised and missing much of their assets. Try to keep well-educated, responsible agents in the business by letting them earn a fair wage.