From: Donald K. Kirk
Sent: July 16, 2007
To: rule-comments@sec.gov
Subject: File No. 4-538


ADV

Dear Ms Morris: I have been a licensed insurance professional and a mutual funds salesperson for over 20 years. In return for ongoing service and advice to my clients I receive trailing compensation much in the way that insurance agents receive renewal compensation. This trailing compensation is typically paid under a written plan adopted to SEC rule 12b-1. This compensation amount is relatively modest; for $10,000. investment into "A" shares it is approximately $25.00. I feel my service to my clients is very important and I believe the elimination of the 12b-1 fees would do considerable harm to those investors who need and want ongoing investment planning advice and counsel. My clients are aware of the 12b-1 charges and the purpose of the charges. ( I do agree that full disclosure of these fees are important for all parties.) I cannot understand why Mr Cox and others with the SEC feel that I shouldn't be fully compensated for doing my job. I have significant expenses in licensed staff, office building etc., so that we can properly serve our clients. I must receive adequate revenues to offset these expenses. I am urging the SEC to reject to eliminate or restrict the payment of 12b-1 fees to registered reps for providing continued service to their clients. Thank you for your consideration of my views on this subject.

NORTHWESTERN MUTUAL FINANCIAL NETWORK
Donald K. Kirk, CLU, ChFC #51685
Financial Representative
311 W. Washington; Pittsfield, IL 62363