From: Clifford E. Marstiller
Sent: July 14, 2007
To: rule-comments@sec.gov
Subject: File No. 4-538


Dear Ms. Morris:

I am writing regarding the current consideration by the Commission of the status of 12b-1 fees paid by mutual funds as compensation to registered representatives such as myself. These fees which are used to provide a relatively small, trailing, service fee to me in consideration of my ongoing service and advice to the client are critical in helping me meet the ever increasing costs of operating my business.

Before placing my client's money in a mutual fund I explain to them, using the prospectus, how the 12b-1 fees are used to pay an ongoing compensation to me for the continued services I provide. Clients understand and expect that I should be paid for ongoing service. While the general public may not know what a 12b-1 fee is, they do understand service fees.

I have no objection to renaming the fee something more descriptive of it's actual use and purpose, but the elimination of the fee would cause a great hardship to myself and other registered representatives who rely on the revenue generated by the fees to provide continued client service.

Thank you for your consideration of my thoughts.

Clifford E. Marstiller

Securities Offered Through Westminster Financial Securities, Inc.
400 Courthouse Plaza SW, Dayton, OH 45402
Member NASD/SIPC