Subject: File No. S7-15-10
From: Gary Orler
Affiliation: Investment Exec, Raymond James Financial Services, Inc.

August 19, 2010

To Whom It May Concern,

I have been a advisor for 27 years, & have always tried to make decisions that were in the best interest of the customer. I have used both B & C shares over the years, until B shares were eliminated by either the Fund Company, or our firm. Since then, I ahve used C shares in order to avoid up fron sales charges. In many of these investments, the client was receiving distribution from IRS`s or may need funds in less than a few years.
The 12B 1 fees allow me to move from one fund to another inside the Fund Company to best manage the clients investments for the best returns to the client.
If these fees are removed, I will be paid next to nothing for my time. I would be happy to disclose the meager income I receive for providing a needed service to my clients.
I can only assume that my income is below those advisors who only look at the income generated, rather than, what is best for clietm.
I have many of my clients who have been doing business with me for over 40 years, when I was a bank lending officer.
I personally beleive that most advisors, especially those of long tenure, do the right thing for the client at a very fair price. By reducing these fees, you will only be reducing the service that is most needed in this difficult economic time!


Gary Orler
Investment Exec
Raymond James Financial Services, Inc.