Subject: File No. S7-15-10
From: Irvin W Rosenzweig, CFP, ChFC, CLU, CRPS, AEP

November 4, 2010

Eliminating C shares and substituting customized share classes with varying advisor fees is highly complicated and not in the interest of the customer. A fee for service advisor already has this option and it is fully disclosed and more easily defined by the client. The client may make an easy choice to determine if the fee warrants the relationships with the advisor. Having the ability to "mark" fees on a fund by fund basis is opening a can of worms relative to customer abuse. The customer would have to analyze each fund within the portfolio to determine the value. The advisor could easily confuse a client and charge a higher fee. On another level, an advisor could charge a low fee to entice a client and then not adequately service the account. Oftentimes advisors are evaluated using assets under management as one aspect of evaluation, conceivably an advisor could inflate their profile by attracting assets due to low fees for purposes of publicity or changing firms, etc. and then drop service immediately after those advisors short term goals are met therefore leaving a customer with a sub par level of service and advice.

Please consider not additionally confusing an already confusing customer/ advisor relationship. Thank you