From: James Owen Davidson
Sent: July 9, 2007
Subject: File No. 4-538

I strongly support the continued payment of fees under SEC Rule 12b-1. Further, I strongly support the concept of clearer, more thorough disclosure of mutual fund fees and expensed to mutual fund investors, in order that investors can clearly understand both the amount and purpose of such fees and expenses.

The amount of compensation is relatively modest; on a $10,000 investment, the annual 12b-1 fee equals 25 basis points, or $25. I earn this fee by providing much-needed service and advice to my clients. These fees provide substantial value to investors--in exchange for a small annual payment, they have access to a financial services expert to answer questions and address their concerns. Without their advisor, investors would have nowhere to turn to (except for perhaps a stranger at the end of a 1-800 phone number) when they need some reassurance in a shaky market or assistance in re balancing their portfolios, or just in re-adjusting their inner compass. If 12b-1 fees were eliminated, advisors would be forced to charge their clients either hourly or asset-based fees to compensate the advisor tfor the time spent servicing their clients' needs. The net effect is that 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. My father used to say "if it isn't broken, don't fix it". I concur. Thanks for reading my email.


James Owen Davidson ChFC,CLU
Central Financial Services
6355 South 56th Street
Lincoln, Nebraska 68516