Subject: File No.
From: David J Reedy
Affiliation: National Association of Insurance and Financial Advisors

November 5, 2010

I have been a licensed insurance professional and registered representative for over 30 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 SEC's proposed use of the terms "marketing and service fees" and ongoing sales charges" 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(NAV)that would allow broker-dealers to set their own sales charge and commission amount.This will affect reps. so they will either start charging fees(usually .50%-1.50%) to everyone in order to provide service or reps will not provide service to investors. Futhermore,reps may exchange funds in order to be compensated since there are no "service fees".The people the SEC is trying to protect the most--middle and lower market investors--will be hurt the most,since they will be deprived of the guidance and service they need and deserve.
My suggestion to the SEC is: why not limit the fee structure the money managers assess the funds and continue to pay "service fees" to reps? This is a win/win for the investor--they get lower fees and reps continue to provide professional advice and service after the mutual fund is purchased.