Subject: File No. 4-538
From: Michael D Crowder
Affiliation: UBS Financial Services, Inc.

June 13, 2007

As a Financial Advisor with approximately $60 million in assets under management, I want to express that 12b-1 fees are important to both me and my clients.

Like many financial advisors, I have embraced the industry's move away from transaction-oriented compensation. The flow of 12b-1 service fees from my book of business has enabled me to shift toward business that produces steady, recurring revenue. This revenue prevents me from having to produce transations just to survive, while providing me with a constant incentive to see my clients' assets grow.

Because I want to see this steady flow of revenue continue and grow, I deliver regular, proactive client service so that my clients receive the most value from their investment costs. I will often recommend that a client shift assets from one mutual fund to another fund offered by the same family, which produces no upfront revenue at all. The service fees I receive provide an incentive to keep assets in place with a fund company rather than look for a different fund company, which might result in more transaction costs for my client (and revenue for my firm).

I agree that it is time to re-characterize 12b-1 service fees to reflect their evolution and importance. However, please know that reducing or eliminating these fees is unlikely to have many positive effects, and seems likely to trigger many unintended consequences.

Thank you,
Mike Crowder