July 19, 2007

I am a licensed insurance professional and mutual funds salesperson.

When I had supervisory responsibility for approximately 55 registered reps in the Baltimore office of MassMutual, I generally encourage them to refer to 12b-1 fees as service fees rather than "trail commissions", thus emphasizing to the customer as well as in the reps' own thinking, that continuing service of the account was expected. I have continued to do this, and find that my clients/customers seem much freer to seek my advice in financial matter when I have explained that I am compensated for it by means of these 12b-1 service fees.

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. 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.

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.