Subject: SEC Review of Rule 12b-1

July 18, 2007

Middle class Americans need the continuing service, guidance and support that are provided by independent financial advisors to achieve their stated investment goals. 12b-1 fees provide a tax efficient means to support the continuing service which these clients require for successful investing.

The multiple share classes made possible by Rule 12b-1 give investors choices by providing them with options in how they pay their financial advisor. The flexibility offered by Rule 12b-1 allows financial advisors to tailor a portfolio to their client's specific needs.

12b-1 fees provide financial advisors with compensation to manage their client's expectations and protect them from falling into common investor traps.

Investment advisory services are simply out of the reach of many small account holders. Financial advisors must have another means of being fairly compensated for servicing these accounts. 12b-1 fees provide the mechanism to insure small investors receive the support and service they need to achieve their financial goals.

Sincerely,

Ms Charlotte Rodriguez
Registered Rep
ING Financial Partners, Inc