July 19, 2007

I am including in my letter the issues raised by FSI because they say all that I want to say very succinctly. I do, however, wish to add to the letter by saying that I have been in the financial planning services industry for 27 years now, almost 20 years as a Certified Financial Planner. Many, many of my clients have been with me for more than 20 years and most are now widows with smaller accounts. These accounts so not meet my minimum account size for new clients but in good conscious I could not send them to another planner. These clients have faith in me, have portfolios that are well allocated and for the most part require only monitoring with perhaps occassional rebalancing. For another planner to take responsibility for these accounts, I will guarantee you they will have to either charge 1% of the assets per year or they will change the investments to other investments to make it worth their while. In either case, these clients will pay more than the very small amount of money I am paid to continue to watch these accounts for these clients. The 12b-1 fees help me hire the people I need to hire to manage and monitor these clients who have so much faith in me and our relationship. I would be happy to discuss this issue with anyone who would like more input.

The following are additional concerns that I have regarding the ruling on 12B-1 fees.

1. Middle class Americans need the continuing service, guidance and support that are provided by independent financial advisors to achieve their stated investment goals. 12b-1 fees provide a tax efficient means to support the continuing service which these clients require for successful investing. The benefits of 12b-1 fees are numerous and include:

.Expanding Investor Choice - The multiple share classes made possible by Rule 12b-1 give investors choices by providing them with options in how they pay their financial advisor. The flexibility offered by Rule 12b-1 allows financial advisors to tailor a portfolio to their client's specific needs.

.Supporting Financial Literacy - Mutual funds send their investors monthly statements, confirmations, prospectuses, annual reports, and other materials. Financial advisors serve the vital role of educators by helping investors to make sense of these essential materials. 12b-1 fees are the compensation financial advisors receive for these efforts.

.Managing Client Expectations - We all know the common mistakes investors make; buying high and selling low, chasing past performance and harboring unrealistic expectations. 12b-1 fees provide financial advisors with compensation to manage their client's expectations and protect them from falling into this common investor traps.

THIS IS A PRIMARY REASON FOR ALLOWING FOR 12b-1 FEES:

.Insuring Small Accounts Receive Service - Investment advisory services are simply out of the reach of many small account holders. Financial advisors must have another means of being fairly compensated for servicing these accounts. 12b-1 fees provide the mechanism to insure small investors receive the support and service they need to achieve their financial goals.

.Subsidizing Additional Services - Independent financial advisors offer their mutual fund clients a variety of additional services including: consolidated account statements, periodic portfolio review meetings, quarterly newsletters, cost basis research, preparation of tax returns, and consulting on other financial decisions. These important services are made possible by the subsidy 12b-1 fees provide.

In conclusion, while it is reasonable to review the investor benefits of 12b-1 fees, it is obvious that the repeal of 12b-1 has the potential to cause great harm to thousands of individual investors who need the support and service of a trained financial advisor. As a result, I urge the SEC to allow Rule 12b-1 to continue to support my efforts to provide needed financial services to middle class American investors pursuing the financial goals.

Sincerely,

Mrs. Gloria Foote
Partner
Financial Focus