Subject: File No. 4-538

July 27, 2007

I would like to express my concerns over the possible proposal being considered by the SEC regarding the reform or elimination of 12b-1 fees on mutual funds. I am a licensed insurance and mutual fund representative who has worked in the field of financial planning for over 28 years. I also am a Certified Financial Planner licensee.

In return for my ongoing professional advice that I offer clients, I receive trail commissions paid on fund accounts that I manage. These commissions are in no way different than renewal commissions I earn from insurance policies that I sell to clients. It is my firm belief that an elimination of trail commissions will severely affect the proper level of service and advice that professionals are able to give their clients. In the end it will force financial planners to charge asset-based fees that in most cases will be larger than the 25 basis points of the 12b-1 fees. Whom does this benefit? Not the average individual investor.

Please reconsider carefully this proposal and take heed of the advice of those of us who work in the field of financial planning. Transparency in fees is a worthy goal, but this proposal will result in a lesser degree of service and/or higher alternate fees paid by the shareholder.

Richard Wyatt