From: Michael R. Clancy
Sent: June 13, 2007
To: rule-comments@sec.gov
Subject: 12b-1 fees


I am in the financial services field, and am series 66 licensed. I was NASD series 7 licensed but no longer need that. 12b-1 fees are the most useless fees for the client to be paying. Very few if any clients actually understand the fee, or even know that they are paying it. Of the few who actually understand a front-end load, the overwhelming majority of those clients don't know that there is an ongoing fee as well. If they knew about the 12b-1, they would be asking what am I paying upfront for! For every broker who whines that the 12b-1 allows them to service the client, what did they do with the upfront commission? If there "service" was worth it, charge for it. Let the client have the option to determine if it's a fair fee or not. Don't bury it where the client doesn't even know they are paying for it.

Michael R. Clancy, CFP, CLU