Subject: File No.4-538 Attn: Nancy M. Morris, Secretary, SEC

July 10, 2007

Ladies and Gentlemen,

Re: SEC Rule 12b-1

For the past 40 years I have had the privilege of serving more than a thousand individual clients as a planning professional, assisting them with the selection and implementation of insurance and investment products - so that they and those they love may enjoy a secure financial life and one filled with "peace of mind." The modest 12b-1 fees paid by each individual, when combined from all my clients, have allowed me to build a staff and infrastructure to provide a lifetime of competent and needed service to these people. As their lives and needs have changed, they have had questions and have needed professionally-trained and up-to-date advice - and they have gotten it, even when they had no need to purchase any new product.

Without 12b-1 fees, I would be forced to charge for service/advice or force my clients to try their luck with a stranger at the end of a 1-800 number. I urge you to go after criminals, cheats and crooks. But, don't upset this 12b-1 fee system which charges the client so little but gives them so much in return, because there are a few bad guys out there. The costs will not be less for the customer for very long if you throw out 12b-1 fees, the customer will pay more. Police the bad guys out of the business.


Reginald N. Rabjohns, CLU, ChFC

Reginald N. Rabjohns, CLU, ChFC
Managing Partner
Rabjohns Financial Group / New England Financial