Subject: File No. S7-15-10
From: Kirk M McGowan

May 5, 2011

I feel that equally strong efforts should be made to inform the investing public that not all brokerage accounts charge a 12b-1 fee for mutual funds even if the fund company imposes such a fee. It should be clearly stated that it is possible for investors working with a brokerage firm to establish an account wherein the investor may purchase funds at NAV and negotiate an ongoing fee structure for the services of the Advisor, thus purchasing a true service rather than a product.