Subject: File No. DF - Other Initiatives
From: Ernie Zack

September 9, 2010

12-B-1 Reform

Please consider that limiting 12-B-1 fees paid on mutual funds will be detrimental to smaller investors. Fee based solutions will be more costly for the exact people the SEC and advisors are trying to help. Most likely, many small accounts will be just be abandoned with your current proposal.