Subject: File No.4-538

July 9, 2007

Dear Sir;

I feel strongly that the payment of 12b-1 fees should be left intact and that instead effort be put forth to make clearer to the consumer, what these fees are for and how much they are. Financial advisors MUST get paid for their services. We are entitled to make a living. I cannot give advise, be held accountable for that advise, and then not be paid for the service I provide. Better disclosure is the better choice if anything needs to be done at all.

Thank you

Michael J. Rogero, CLU, ChFC
Financial Design Associates