Subject: File No. 4-606
From: Stuart Armstrong, CFP
Affiliation: Centinel Financial Group

August 17, 2010

The most important message I have about continuing 12b1 fees is that they provide ongoing compensation to me for continuing to service and guide my clients with commission based investments. I am a Registered Representative and a Registered Investment Advisor. I've been practicing since 1986. The early days investors had only 8.5% up front sales charges with no service or 12b1 fees. I never liked that approach but found the lower up front sales charge of typically 5.75% and down with 12b1 fees to be a much better formula for overall compensation and servicing. Without 12b1 fees, the incentive to move the funds for some brokers to a new commission fund would be too tempting for some and not clearly in their best interest in many cases. The other side of it is No Compensation and then less incentive to service the funds.

I agree whole heartedly that many fund companies charge too much and that perhaps C Shares and even 12b1 A shares can be abusive with excessive 12b1 fees. But eliminating low cost providers 12b1 fees for fund companies like American Funds makes no sense.

What the SEC should be doing is setting a policy that looks at the way American Funds is set up. And model after that. Additionally, the SEC could eventually have the C shares convert to A shares after a length of time like 10 years or something like that.

But please DO NOT take away the incentive and the compensation that 12b1 fees provide to responsible brokers who do right by their clients.

Stuart Armstrong