From: Kenny Divelbiss
Sent: July 9, 2007
To: rule-comments@sec.gov
Subject: File No. 4-538


To Whom it May Concern:

I believe the elimination of 12b-1 fees would do considerable harm to those investors who need and want ongoing investment planning advice and counsel. A significant majority of my clients expect our office to be available and to respond quickly to a variety of questions regarding their investments. I have never received complaints from my clients about the small amounts they are charged for the services I provide to them. My clients expect me to be compensated for helping them achieve their long-term financial goals. If 12b-1 fees were eliminated, while the client might save a small amount in 12b-1 fees he or she would end up paying a much larger amount in hourly or asset-based fees to receive the same service.

For these reasons, I urge the SEC to reject any proposal to eliminate or restrict the payment of 12b-1 fees to registered representatives for providing continued service to their clients. Thank you for your consideration of my views on this subject.

Kenny Divelbiss, CFP, CLU, ChFC, CFS, AEP, MSFS, CASL, CAP, REBC
Wealth Management Advisor
6301 Waterford Blvd, Ste 440
Oklahoma City, OK 73118