Subject: File No. S7-15-10
From: Adam M Sachs, CFP
Affiliation: National Association of Insurance and Financial Advisors (NAIFA)

November 2, 2010

I have been providing financial advice for the last 17 years. I try to speak to my clients once a quarter and meet once a year to help them with their investments, risk management and financial goals. Rellallocating their investments to make sure they do not become more aggressive and or to take advantage of new asset classes is part of this process. Because investment management is so interconnected with other parts of a financial plan, I attempt to make sure that any changes to beneficiary designations are made to their IRAs especially if new estate planning documents had been implemented. Many of these clients, prefer to use directly owned mutual funds instead of paying for "wrap account" fees which generally costs more on an ongoing basis knowing they limited to the fund family. They understand that a .25% 12b1 fee provides more than a reasonable compensation for that overall service.