Subject: File No. S7-15-10
From: Edward J Mallon, CLU, CFP
Affiliation: President, Secure Planning Inc.

August 27, 2010

The indroduction of C shares allowed firms and representitives to change their stradegy from selling to giving comrehensive servicing.
With A shares a representitive must continually be selling new clients or possible new sales to old clients. C shares, with their current pricing and payouts, have allowed representitives to spend more time examinging the needs and changing expectations of their clients. With better servicing clients are more likely to stay invested while receiving good advice from the representitive.
As consumer's needs change they can easily be hurt as they move from representitive to representitive looking for ongoing advice and buying new A shares. This is not the case with C shares.
In selling C shares the representitive's compensation is small and they must be committed to maintaining a client for many years before compensation reaches that of the initial compensation of an A share.
It is our belief that C shares, as currently priced and compensated, are a better consumer product.