Subject: File No. S7-15-10
From: Jim Startzell
Affiliation: Registered Representative FSC Securities

November 11, 2010

The changes recommended in 12(b)2 are trivial to the client and will reduce service to small accounts (less than $100,000).
We've all seen the charts where 91% of a clients' return is asset allocation (which types of investments, stocks, bonds, etc.). In other words, it is much more important whether they are in global equities or government securities than a less-than-1% fee.
Look at any years Callen chart to tell you that choosing (or not choosing) a small cap fund is paramount to return compared to 12(b)1 fees.