Subject: File No. S7-15-10
From: Patrick Allaire
Affiliation: President/CEO, Allaire Financial Strategies

August 30, 2010

In a world confused by financial products adding another layer of confusion would only aid the flight to safe type investments and hurt teh consumer further in their quest for reaching their retirement and accumulation goals.

I favor the conversion of C to A shares after a 10 year period as teh design of teh share class was for short term investment results. It does have the potential for the advisor to change investments as the conversion becomes evident, however, I have yet to see a consistant performance that should not be reviewed after 10 years.

I am not in favor of account-level sales charges, the message that would deliver is that all funds are equal, that the only focus teh consumer should review is who is willing to work cheaper, it would not encourage planning, just price comparisons. Eventually, the smaller consumer, serviced by inexperienced advisors who positioned themselves as price sellers, would be hurt.

Thank you for considering this point.

Mr Patrick Allaire
Allaire Financial Strategies