Subject: File No. 4-606
From: John V Picone
Affiliation: CFP

August 25, 2010

I am commenting on the proposed changes to C share structure and commissions. I have been in business 29 years, and service the middle-upper class investor. Many times these clients don't have enough funds to invest in our fee based platform, so I must use some type of mutual fund allocation. I don't like using A shares since the upfront fee is so large and takes a big bite out of the immediate investment. In keeping with the fee based structure, i.e, onging service fees, we like to use C shares. We make much less upfront, but it pays us over the long term for service and financial planning. I have many clients over 20 years, and they often refer their children or grandchilden to us that don't have sizable funds to work with.

The C share allows us to work with these people, in an independent unbiased way (we receive the same fee on almost all C shares so we have no bias towards higher commission funds). Eliminating this fee structure would make it much more difficult and costly for these clients to work with us. I don't want a big commission up front. We want to work with our clients over the long term and receive a fair compensation for that service.

I hope this helps explain our position on this Thank you


John V. Picone, CFP
Picone Financial Partners
Bonita Springs, FL