From: Pete Newman
Sent: July 9, 2007
Subject: File No. 4-538

Ms. Morris:

My name is Pete Newman. I am a licensed life insurance agent in Texas. I am NOT currently licensed to offer securities, so the opinion expressed here is not predicated on any concern for personal financial gain.

I am very disturbed about the current discussion at the SEC regarding SEC Rule 12b-1 fees and the possible repeal of this important aspect of the mutual fund distribution system.

The mutual fund distribution system must have qualified investment advisors in place to provide on-going service and consultation to US investors. Without these fees the number and quality of investors available to assist investors will decrease, or the cost of advice and service will increase.

Mastering and maintaining the knowledge and skill required to support the sale and service of mutual funds is time consuming and expensive. These fees help individual advisors off-set ( but do not completely cover) the ongoing expenses of maintaining an investment advisor practice. The very modest amount of current fees, about $25 per $10,000 invested, has not been a concern for me. I seriously doubt that investors have expressed serious concern regarding these fees. Investors that are complaining may well be using this issue as a proxy for what are likely other frustrations related to fund performance.

Please reject any proposals to stop or adversely change the use of 12b-1 fees.


Pete Newman, CLU, LUTCF
Manager Life Agent Training and Direct Sales Germania Life Insurance Company PO Box 645 Brenham, Texas