Subject: File No. 4-538
From: Ron DeLegge
Affiliation: Index Investing Show

June 19, 2007

Here's my official proposal for 12b-1 fees: The SEC should rename them B-52 fees because they bomb investor's portfolios with unnecessary fees and hidden costs.

Particularly alarming is the usage of B-52 fees in mutual funds that are closed to investors. What's the point of collecting marketing and distribution fees for funds that aren't marketing themselves? It's a contradiction.

Financial intermediaries still deserve to be compensated for their work, but B-52 fees aren't the way to do it. They should find a new way to get paid. Between them and mutual fund companies, I'm sure they'll come up with something.

Again, financial advisors deserve to get paid, but the investing masses DESERVE fair disclosure and 100% transparency in how their money is transmitted for those payments. Disclosure isn't disclosure unless it's disclosure. To me, B-52 fees being buried in a thick uncomprehendible booklet doesn't qualify as fair disclosure, but then again I'm not a securities attorney, so what do I know?

BOTTOM LINE: When getting paid is in direct conflict with fair disclosure and 100% transparancy - as B-52 fees are, then it behooves the Agency to take corrective action.