From: Matt Miller
Sent: July 12, 2007
Subject: File No. 4-538

I have been in the financial services industry since 1979, and am a CFP (as well as a CLU, ChFC, CFS and CSA.) I have always disclosed the intrinsic value of 12b1 fees paid by mutual fund companies to my clients: clearly, it is recurring income for me; but, clients also understand that these fees are costs they pay to ensure they get timely, periodic and honest advice. I also have always told clients that these fees are small, $250.00 for every $100,000 of money they have invested, but they are important to the mutual fund companies as well: they don't want to lose their customers' assets, nor do I, and this is a simple way to compensate the registered representatives for recommending a particular mutual fund family's menu of choices.

Some Certified Financial Planners are fee only; and I do charge fees through my RIA, but not on every single case, as they are not necessary. In order to continue to service my investment clients in lieu of 12b1 fees, I would have to charge an hourly rate for the time I spend with these families and small businesses. In my mind, the 12b1 fee is analogous to insurance company renewal commissions.

Finally, in my investment accounts, I have used no-load mutual funds (which have no 12b1 fees) as well as Exchange-Traded Funds and individual securities. But just like using a Class A, B or C share mutual fund, these securities MUST be appropriate for the client, their goals and risk tolerances. A number of mutual funds in different asset classes held for long periods of time will generally accomplish the client's goals; however, they must stay in the investments, and again the on-going 12b1 fees compensate the financial advisor for telling clients to buy and hold, not get out of the markets when things are going badly.

There are most certainly American consumers that do their own investing: funds, ETFs and stocks. For these folks, no-load funds and E-Trade types of accounts are entirely suitable. But, there are lots and lots of American consumers who NEED help, and who are willing to pay a competent advisor for that help.

Thank you,

Matt Miller, CLU, ChFC, CFP, CFS, CSA
Registered Representative, MML Investors Services, Inc.,
Massachusetts Mutual