Subject: File No. 4-538
From: Rick Sany

June 13, 2007

If 12b-1 fees are eliminated, I believe most clients will pay more for the advice they receive. Accounts would be moved to a fee-based platform or wrap program, which over the long run are more expensive for clients to own. Instead of 25 basis points, an advisory fee of 1% or more per year would hurt the client. Smaller clients would be most affected by a change of this kind.