Subject: File No. S7-15-10
From: William A. Greulich
Affiliation: Certified Financial Planner

August 24, 2010

Regarding the 12b1 proposal.
I use Class C shares for most of my clients entering retirement years (59 and up). The C shares are commonly compared to A shares in expenses. I think this is misguided. I use the C shares as a "working persons" alternative to a pure Fee based plan. If you consider the fact that a typical C share's expense is between 50 and 75 bps over the comparable A share then it may appear as a bad value if kept for 10 plus years. The reality is the C share should be compared to a Fee base plan that charges a 1% or higher fee plus you must add in the A shares expenses minus any 12b1s. The C share will always be less expensive therefore a better value to the Client. I have no problem with the Fee based world but to constantly use the A-C share comparison is not "real world" use.
Many of my clients have a C share asset base between 100K and 900K. For them I provide an ongoing service plan to help them keep their portfolio's intact and consistant with their long term needs. I get paid 1% annually for that service. The C share expenses including the 12b1s allow me to service my clients.

Thank you