From: Scott Dickerson
Sent: June 14, 2007
To: rule-comments@sec.gov
Subject: 12B!


I have a large number of small investors who have less than $25,000 under management with me. A typical 12B-1 fee would pay me $56.87 at that amount, barely enough to compensate me for monitoring, managing, advising, newsletters, service calls, updating new account forms, compliance related issues, etc. I am already losing money on most of these accounts. Without a 12B-1 fee, which for many of these accounts is the sole revenue, I cannot afford to keep these clients on the books. I would be forced to "fire" them as clients and let them fend for themselves. If you doubt this, then look at the increasing rising minimums from no load funds like Vanguard. They recognize the true cost of small accounts. These fees are disclosed. If the investor is ok with the fee, then why should the government tell them it's not ok? The little guy is just losing out on places to help them invest. In some ways, I hope they end these fees because I would immediately let go most of these clients. It would give me a reason to let them go and it could clean up my book. Is this doing the small investor a service? I think not. If this come about, it will only reinforce an industry trend toward high minimums for managing accounts and charging fees--better for me and the value of my practice, but again, probably not so good for the small investor.

Scott Dickerson, ChFC
Dickerson Financial Services, Inc.