From: Richard T. Suro
Sent: June 13, 2007
To: rule-comments@sec.gov
Subject: 12b-1 ruling


I am writing to you with regard to the upcoming meeting on the 19th to discuss the future of 12b-1 fees. I've been securuities licensed since 1978 (series 6, 22, 63) and operating as an independent advisor for the past 8-years. Being out on my own running a small practice has become an ever increasing dificult task from a financial standpoint for the past 5yrs. I have built a small but loyal client base which represents approximately 8.5 million dollars of assets in 12b-1 fee paying accounts. Though in the big picture just a mear drop in the proverbile bucket it represents about $21,000 a year of MY INCOME. Put in other terms, about 21% of my gross income. Between office rent and associated expenses, plus E&O, affiliation fees, software fees, license's and various state registration fees and lastly advertising fees my core business expenses run close to $25,000 per year. Take away my 12b-1 fees and I'm out of the business I've been in for nearly 32-years. My typical client has about $125,000 invested with me though I do have several larger clients, many of those I service fall through the cracks in the floor of the larger brokerage's. These are people whom are told that frankly their accounts are too small to be considered by these firms. Many of these accounts started with less then $5,000 when first opened. These are good hard working individuals who are ALSO entitled to finacial help and guidance, and the hope of being able to one day retire as well. Only about half of my appointments come to my office many times I drive to see them. This has been part of the personal service that I have always provided and I believe why my client retention is nearly 100% for the past 12-yrs. My licenses and history is spotless, never a single complaint as many of my independent peers. Seems to be the more that the big brokerage's take in the more problems develope in their shops. Once again the little people will be hurt. Either those small office's like mine in the business or the million's of hard working individual's who don't have "enough" money to be considered a valuable asset. Go after the thousand's of crooks in this business selling EIA's too EVERYONE they meet and the "one size fits all" mentality they operate on.

Thanks for listening,

Sincerely, Richard T. Suro

Richard T. Suro, Registered Representative
Richard T. Suro Associates, Inc.