Subject: SEC Review of Rule 12b-1

July 6, 2007

I am writing to voice my opinion over 12b-1 fee discussions.

I have been a registered rep for 21 years and I currently have $170 million in client assets for more than 500 people. Average account size: $304,000. Certainly middle America.

I think that 12b-1 fees should be renamed "advisor service fee" and be more prominently disclosed. Other than that, no changes are needed.

Investors are well served by having their advisor receive ongoing compensation. One benefit is the decreased likelihood of churning.

If 12b-1 fees are eliminated, I will have to convert brokerage clients to fee-based clients. The advisory fee will be higher than the 12b-1 fee given the structure and regulation of advisory accounts.

As someone in the trenches for more than 21 years, I think I could add substantially to the debate and I offer my services in future testimony or the like.


Mr. Graham Parsons
Registered Principal
LPL Financial Services