From: Paul L. Magnano
Sent: July 23, 2007
Subject: File No. 4-538

Nancy M Morris
100 F Street, NE
Washington, DC 20549-1090

Nancy Morris:

These are my comments and reaction to 12B-1 fees. Most of my business is directed to helping people with their life insurance but I do have 400+ investment accounts with approximately 65,000,000 of assets. It has been my decision to try and provide investment product solutions at the lowest cost possible to my clients. It seems that for most people who have a long term horizon buying A shares is the most efficient. So my compensation is less than if I suggested B or C shares.

An alternative would be to charge a fee which is very much in "vogue." Clearly, the 12B-1 fee would be less expensive to the client and I have resisted, at a financial loss to myself, in charging fees. So the alternative to the 12B-1 fee clearly is only more expensive to the consumer.


Paul L. Magnano, CLU, ChFC