Subject: File No. S7-15-10
From: Roscoe O Orton

November 4, 2010

I have been a licensed insurance professional and registered representative for over _25_ years.
I support new SEC rule 12b-2, which would continue the 25 basis points fee that is used to ensure investors receive ongoing service and advice, and the SECs proposed use of the terms marketing and service fees and ongoing sales charge in place of 12b-1 fees to improve transparency in disclosure documents.
However, I strongly object to the SEC permitting mutual funds to issue a new class of shares at net asset value that would allow broker-dealers to set their own sales charge and commission amount.

The result of that action will be to send all middle and lower income investors to no load funds with no professional advice. In tough economic times, with no advisor input the average investor will get scared and pull funds at the worst time possible. With an advisor partner, they can be reminded that staying invested will win over the long run.