Subject: File No. S7-15-10
From: Michael McCuistion
Affiliation: Registered Rep., ING Financial Partners

August 25, 2010

I am writing in regard to the recent changes for Class "C" mutual fund shares, trails fee structure. The biggest part of my practice is fee based asset management. With this approach, I review my client`s portfolios on a monthly basis, making recommendations for adjusting the portfolio, typically two to six times per year. Some of my clients investments are in environments that don`t facilitate this type of arrangement (The University of Missouri`s 403(b) Program for example) so I use Class C mutual fund shares to provide a similar cost to the client and a similar (reduced) compensation structure to me. The recent changes may make take away the feasibility for me to offer this service to some of my clients since the "C`s" will convert to "A`s" after several years. This reduces the compensation to an unreasonable level, for the service provided. This action seems to be another example that creates unintended consequences for smaller client accounts as larger economies of scale are required for financial professional to justify providing such a valuable service to their clients.

Mr. Michael McCuistion
Registered Rep./IAR
ING Financial Partners