July 19, 2007

I have been a licensed insurance professional and mutual funds salesperson for nearly 30 years.

In return for providing ongoing service and continuing guidance to my clients regarding their investments, I receive trailing compensation much in the same way I receive renewal commissions on the life and disability income insurance policies I sell. This trailing compensation is typically paid under a written plan adopted pursuant to SEC Rule 12b-1.

I live and work in a small city. Most of my clients are mainstream Amercians. The vast majority of my clients accounts have less than $50,000 in them. I prmarily sell A share mutual funds. The amount of trailing compensation I receive from most of my accoounts is modest. On a $10,000 investment in a mutual fund's "A" shares, the annual "12b-1 fee" that is paid for providing ongoing service equals 25 basis points, or $25. Investors receive substantial value for these fees--in exchange for a small annual payment, they have access to a financial services expert to answer their questions and address their concerns. Without a proffesinal provinding guidance, investors would have nowhere to turn to (except for perhaps a stranger at the end of a 1-800 phone number) when they needed some reassurance in a shaky market or assistance in establishing and rebalancing their portfolios, understanding their investments and the investment choices available.

I believe the elimination of 12b-1 fees would do considerable harm to those investors who need and want ongoing investment planning advice and counsel. A significant majority of my clients expect our office to be available and to respond quickly to a variety of questions regarding their investments. I have never received complaints from my clients about the small amounts they are charged for the services I provide to them. My clients expect me to be compensated for helping them achieve their long-term financial goals. 12b-1 fees allow my clients to have service that wealthy fee paying clients get. Eliminating 12b-1 fees would shut my clients out ouf investing because they would not likely work with an 800 number. They will not pay hourly or asset-based fees to receive the same service.

For these reasons, I urge the SEC to reject any proposal to eliminate or restrict the payment of 12b-1 fees to registered representatives for providing continued service to their clients.

Thank you for your consideration of my views on this subject.