Subject: File No. 4-606
From: Frederic S Scarpulla
Affiliation: registered representative

August 6, 2010

I am a registered rep with LifeMark Securities in Rochester, NY. We work with clients, not all affluent familes or businesses. Please do not take away our 12b1 fee's as we spend countless hours servicing these clients via phone , mail,updating direct deposits, providing change of beneficiaries, client service meetings (with their CPA's or other family members), in our office and at client businesses. For every $1M of assets you are talking about $2500 of gross compensation (after broker dealer approx. 20% less) registered rep's. Our practice works with American Funds whose A shares are among lowest costs in industry, even when add in 12b1 expenses are much lower than many wrap or brokerage plans are charging clients.
While RIA planning does have its place for certain clients (those that have 50K or more to invest and are more sophisticated) we would like the oportunity to service our clients that have Fidelity, American Funds or Oppeneheimer Funds with us for years to come...why not cap 12b1 fee's for 10 or 15 years as a thought? At 25 bais points per 1M of assets gathered, providing service in a a competitive marketplace seems like an inexpensive solution.
Thank you very much...
Frederic S. Scarpulla
registered representative/LifeMark Securities