Subject: File No.
From: Robert A Matson
Affiliation: CEO, Robert A Matson CLU, ChFC

November 5, 2010

As a financial advisor and insurance professional for almost 30 years, I wished to add my comments relating to the proposed introduction of the new SEC rule 12B-2.
While I support greater transparency for clients to understand the on-going expense of 12B-1 fees, I am fearful that the ability of broker-dealers to set their own fees will result in a situation where I will no longer be able to service those long-term clients that are not able to be a part of an asset-based fee program due to the required investment minimums of such programs (typically $100,000 or above).
Those individuals who need my services the most will have to rely upon their own self-direction as I will not be able to afford to service them. The very people that the SEC needs to protect the most would be put at greater risk, since they will be deprived of the guidance and service they need and deserve.
Thank you.