Subject: File No. 4-538
From: Robert J McClure, CFP
Affiliation: Independent Registered Investment Advisor

June 18, 2007

Dear Sirs:

I am a 58 year old CFP (Certified Financial Planner) and an independent RIA (Registered Investment Advisor) located in Peoria, Illinois.

I work as a financial planner and as an investment consultant with a conservative clientele many of whom have less than $1 million invested. I have encouraged all of them to invest in high quality, conservative funds, most of which pay a .25% 12b-1 fee.

These 12b-1 fees pay for the service which I provide to these clients many of whom are retired and who don't invest new amounts additionally. The 12b-1 fees encourage service by providing compensation in the service direction versus compensation based only on new sales. Also, the 12b-1 fees aid marketing since satisfied Clients refer other individual investors who seek good service.

To eliminate 12b-1 fees would certainly hurt many investors but especially older investors.

Were if not for these 12b-1 fees, I could not have afforded to service my clientele in the manner I have and their investment results would very likely have suffered tremendously. One only has to remember how terrifying the market downturn of 2000 - 2002 was for the average investor. During the 2000 - 2002 downturn, I was on the phone almost daily assisting and encouraging these clients in some manner. Their tenacity as investors has been rewarded the greatly. Many of these clients have stayed invested for 10 - 15 years which has been much to their advantage. To eliminate 12b-1 fees and skew compensation only to new purchases would be a terrible mistake and would cause many of these older clients to suffer.

In my many years of experience in personal finances, the stability of an investors investment plans depends to a very large extent on the advice, encouragement, and service they receive. Service matters can be complicated and intricate. The 12b-1 fees cover this advice and service. Without the built-in 12b-1 fee, I would very likely have to charge clients through some form of "wrap" arrangement -- maybe 2-4 times what they pay through the 12b-1 fee.

I believe that 12b-1 fees represent a "good deal" for my clients when considering the service they receive.

I believe that 12b-1 fees promote not only individual investor stability but also promote overall market stability by keeping people invested.

Industry-wide, I believe that 12b-1 fees probably help prevent investment "churning" because they represent a "fair" compensation for service and promote referrals and therefore lessen the importance of new commissions on new sales.

For all of these reasons, I hope you will allow 12b-1 fees to continue exactly as they are -- a vital of the investing picture for individual investors, especially the elderly, and for investment advisors.

Sincerely,

Robert McClure,
CLU,ChFC,CFP