Subject: File No. 4-538
From: Martavius D Jones
Affiliation: NASD Registered Representative

June 13, 2007

Recent industry publications have reported on the SEC's review of Rule 12b-1. I am an independent registered representative affiliated with a small broker-dealer and I don't have the marketing bugets of the large broker-dealers. While I can offer the same SERVICE as my much larger competitors and the the same QUALITY products (since most of us generally have the same products from which to choose), I often win on PRICE. The main reason I went independent was because most brokerage and financial advisory firms charge wrap and asset-based fees of 1% or greater, when clients are buy-and-hold investors often with mutual funds as the primary financial product. I feel it is not in the best interest of the client to have them in wrap or asset-based accounts if they are buy-and-hold investors.

I am able to compete because I offer clients the same SERVICE and QUALITY for a lesser price because my compensation is from 12b-1 fees that are generally 0.25%. On a $100,000 mutual fund account 12b-1 fees are $250 per year A wrap or advisory fee, instead of a 12b-1, for the same client would normally be $1,000 annually.

The small investor would be harmed the most if 12b-l fees were eliminated because financial professionals would only have client relationships with those clients that could generate fees of at least $2,500 per year. Most of my clients have accounts less than $100,000 in investable assets and I'm able to service the accounts that the major firms have already relegated to call centers.