July 19, 2007

I am a licensed insurance and series 6/63/65 professional.

Ongoing service and continuing advice provides value to clients in much the same way that insurance agents receive renewal commissions on the life insurance policies they sell. This trailing compensation is typically paid under a written plan adopted pursuant to SEC Rule 12b-1.

The amount of this compensation is relatively modest. Investors receive value for these fees--in exchange for a small annual payment, they have access to a financial services expert to address their needs. Without an advisor, 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 rebalancing their portfolios, understanding their investments and the investment choices available. Equally important is understanding the role such products play in meeting clients' overall objectives.

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 - the law of unintended consequences would likely come into play. I do not recall received complaints from clients about 12b-1 fees.

If 12b-1 fees were eliminated, while the client might save a small amount in 12b-1 fees he or she would end up paying a much larger amount in hourly or asset-based fees to receive the same service.

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.