From: JoNell Hermanson
Sent: July 9, 2007
Subject: File No. 4-538

Nancy M. Morris, Secretary
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C.20549-1090.
Re: File No. 4-538

As a member of the financial services industry and a developer of variable insurance products I strongly urge the SEC to repeal 12b-1 fees for variable products. Insurance companies have used 12b-1 fees to bake in their own margin to meet their required ROE. In effect, 12b-1 fees have become a "shell game" for insurance companies and have allowed them to camouflage their profit margin as investment management fees.

JoNell Hermanson
M Financial Group
1125 N.W. Couch Street
Suite 900
Portland, OR 97209