Subject: SEC Review of Rule 12b-1

July 20, 2007

I am writing to express my concerns about the SEC's ongoing review of Rule 12b-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:

The main reason for the fee is to pay for investment distribution expenses and we brokers and advisors are a 'distribution arm' of for mutual fund and variable annuity industry.. Without us, most people would never become investors, rather just spenders, bank account savers, thus missing out in 'growth of capital' for their future retirement $$'s. Believe it or not, left to themselves w/out proper professional help from brokers and advisors like me, most people wouldn't know how or where to invest their $$, whether there was a 12b1 fee or not, or the management fee was .12% or 2.12%, they just wouldn't invest. Then there are those that feel they can do it on their own, can get all the proper info via research and internet, yet will not 'pull the trigger' w/out a professional to be with them to give positive or negative advise. I can assure you that for most people they do not want to invest on their own any more then the want to vacation on their own. They need and want a p rofessionals be w/ them and to work with them and the additional 12bq fee is a reasonable method to compensate brokers and advisors in order to continue to work w/ these investors on an ongoing basis as a 'distribution arm' in the mutual fund industry. Please call me to discuss these issues or to get 'in field' information about this topic. You, or one of your staff , are invited to sit w/ me for 5 business days, for 8 hours a day, and count the time and listen to the content of my telephone calls (100% of the day) assisting and helping my 100's of clients that have not made a transaction in many years, therefore no 'commissions' to support my efforts, yet the clients get serviced and are financially satisfied, because I can afford them the time as a result of the 12b1 fee I get to continue to distribute and keep clients invested in various investments that have 12b1 fees. I expect your call. 714-974-4500.


Mr Thomas Hoban
Royal Alliance