From: Robert Keenan
Sent: June 19, 2007
Subject: File Number 4-538 12b-1 fees

Dear Sir/Madam;

Our firm's income from 12b-1 fees is 35% of our gross revenue.

Without these 12b-1 fees, for our clients, we would be forced to either (1) provide no service whatsoever or, (2) transfer the accounts to RIA accounts, where a much higher fee is charged, or (3) churn the account. None of these options are desirable.

On accounts requiring re-balancing only when the client goals change, 12b-1 fees are the most cost efficient option available to both us and the client.

Without 12b-1 fees, every time a change was needed in a client account, we would sell the fund and purchase another fund from a different fund family. This would generate a commission, rather than having a commission free exchange within the same fund family.

Doing away with 12b-1 fees is a very bad idea.

Robert Keenan
St Bernard Financial Services, Inc.
Member NASD & SIPC