From: Mario A. Santos
Sent: July 9, 2007
Subject: File No. 4-538

Dear Sirs/Ladies:

Please do not eliminate 12b-1 fees with mutual funds because 12b-1 fees provide an alternative to upfront sales load which immediately lowers the investment principal of clients. The solution is to review the wordings of the explanation for 12b-1 fees, simplify in plain English, explain the advantages and disadvantages to the clients.

One advantage with 12b-1 fees is to help increase the probability that one registered represenative has the monetary incentive to continuously take care of the client years after the sale, which may or may not be absent in the case of advance sales load since the registered rep already got all his commissions.

Without 12b-1 fees, clients might be forced to be charged hourly or asset fees. Hourly fees could range from $100 to $250 an hour. Many middle income clients cannot afford to pay for that. For example, at a $10,000 principal invested, the 12b-1 fee could be $25. Which cost can a small investor afford, $25 or $!00, or $250?

Many financial planners who charge asset fees, will only take care of clients with $100,000, even $500,000 of investable assets. They do not take care of small clients such as those being charged 12b-1 fees (those with only $10,000 or $25,000 of investable assets, for example).

The more choices given to clients, the better. Maintain 12b-1 fees.

Thanks for allowing me to share my thoughts.

Mario A. Santos, CLU
Not a registered representative