Subject: SEC Review of Rule 12b-1

July 5, 2007

All of my clients are commission based. A fee based model for providing them service would be too expensive for them. However they benefit from the service provided in their current commission based model.

ThereforeI am writing to express my concerns about the SEC's ongoing review of Rule 12b-1. 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:

- my ability to meet my clients goals and desires;

- my ability to provide a person with whom they can discuss their particular investments and the correspondence they recieve from the mutual funds and insurance companies;

-12b-1 fees provide me with adequate compensation to assist my clients in achieving their investment, retirement and financial goals.

Investment advisory services are simply out of the reach of my clients, however financial advisors, like myself, who provide vital services to clients such as mine deserve to be 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.

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 Martilias Porreca