Subject: SEC Review of Rule 12b-1

July 5, 2007

I am writing to protest blanket action in the strongest of terms. Over my nearly twenty five years of working with the public, all but a handful wanted me to be compensated for my time, technical expertise, and their benefit derived from my own service on their behalf.

I have been extremely fortunate to have survived in a business in which regulatory efforts have directly and significantly increased my overhead and decreased my commissions because of the unethical or illegal acts of unrelated others.

Now, in addition to my initial compensation being nearly half of what it was two decades ago for what is nearly thrice the paperwork today, I find you wish to terminate the less than subsistance service fees I get for otherwise uncompensated labor faithfully provided to my clients.

Let me be clear, you burdon the honest and competent financial adviser at the loss of the otherwise deserving majority of taxpayers who have no desire to become stock-players or temporary not-so-no-load mutual fund guru's.

Truly, middle class Americans need the continuing service, guidance and support that are provided by independent financial advisors to achieve their stated investment goals. 12b-1 fees provide a tax efficient means to support the continuing service which these clients require for successful investing. The benefits of 12b-1 fees are numerous and include:

.Expanding Investor Choice - The multiple share classes made possible by Rule 12b-1 give investors choices by providing them with options in how they pay their financial advisor. The flexibility offered by Rule 12b-1 allows financial advisors to tailor a portfolio to their client's specific needs.

.Supporting Financial Literacy - Mutual funds send their investors monthly statements, confirmations, prospectuses, annual reports, and other materials. Financial advisors serve the vital role of educators by helping investors to make sense of these essential materials. 12b-1 fees are the compensation financial advisors receive for these efforts.

.Managing Client Expectations - We all know the common mistakes investors make; buying high and selling low, chasing past performance and harboring unrealistic expectations. 12b-1 fees provide financial advisors with compensation to manage their client's expectations and protect them from falling into this common investor traps.

.Insuring Small Accounts Receive Service - Investment advisory services are simply out of the reach of many small account holders. Financial advisors must have another means of being fairly compensated for servicing these accounts. 12b-1 fees provide the mechanism to insure small investors receive the support and service they need to achieve their financial goals.

.Subsidizing Additional Services - Independent financial advisors offer their mutual fund clients a variety of additional services including: consolidated account statements, periodic portfolio review meetings, quarterly newsletters, cost basis research, preparation of tax returns, and consulting on other financial decisions. These important services are made possible by the subsidy 12b-1 fees provide.

In conclusion, while it is reasonable to review the investor benefits of 12b-1 fees, it is obvious that the repeal of 12b-1 has the potential to cause great harm to thousands of individual investors who need the support and service of a trained financial advisor. As a result, I urge the SEC to allow Rule 12b-1 to continue to support my efforts to provide needed financial services to middle class American investors pursuing the financial goals.


Mr. Steven Weinstein, CFP
Registered Rep
Mutual Service Corp