Subject: File no.4-538

July 10, 2007

Dear sir:

The current 12b-1 fees ensure that my clients get the service they so richly deserve. Those fees do not adaquately reflect the amount of time that I spend on my accounts. However, it at least helps defray the cost for my increased time necessary to service my investors.

I choose, at this time, to not charge my clients an advisors fee or by the hour to manage their money. The 12b-1 fee is a lot less than I would have to charge to service their accounts.

My clients understand, and expect to pay some fee for having their advisors oversee their account. They also realize that the 12b-1 fee is less costly than most managed accounts.

I hope you will take this into consideration before doing away with the 12b-1 fees. It is not in the best interest of our clients to do so. On the contrary, most of their expenses would increase if the 12b-1 fees were eliminated.

Hal Nickle,CLU
Regostered Rep. MMLISI